Articles and Blogs

On January 12, 2017, the Department of Health and Human Services Office of Inspector General (“OIG”) published the “Health Care Programs: Fraud and Abuse; Revisions to the Office of Inspector General’s Exclusion Authorities” Final Rule (“Final Rule”) revising and expanding its authority to exclude individuals and entities from participation in federal health care programs.... READ MORE

On December 20, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a Final Rule that included several changes to the recently implemented Comprehensive Care for Joint Replacement (“CJR”) program. The CJR Model is a retrospective bundled payment program limited to lower extremity joint replacement (“LEJR”) procedures and is designed to encourage hospitals... READ MORE

Background On December 20, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule (the “Final Rule”)1 creating three new episode payment models (“EPMs”) covering services provided to Medicare beneficiaries admitted to certain Inpatient Prospective Payment System (“IPPS”) hospitals for heart attacks, coronary bypass surgery or surgical treatment of hip or... READ MORE

Review of the New Quality Assessment and Performance Improvement Condition This is the first article in a series discussing CMS’s pre-publication copy of the Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing, with only a few changes, the significant changes they proposed to... READ MORE

On January 3, 2017, Governor Rick Snyder signed House Bill 4598 (“HB 4598”) into law. HB 4598 adds Part 171 (Midwifery) to the Public Health Code and provides new licensure requirements for the practice of midwifery in Michigan. Effective immediately, the bill establishes midwife licensure and scope of practice requirements, including: Prohibiting an individual... READ MORE

The supply chain continues to be the second largest and fastest growing expense for health care systems, second only to labor costs, making this an area of untapped cost savings opportunity and an area ripe for leveraging supply chain as a strategic driver of savings. Because the procurement of goods and services impacts nearly... READ MORE

On December 27, 2016, the Food and Drug Administration (“FDA”) issued final guidance (the “Post-Market Guidance”) outlining steps that medical device manufacturers and health care systems should take to monitor, identify, understand and address cybersecurity risks once medical devices and mobile medical devices have entered the marketplace. The Post-Market Guidance follows October 2014 FDA... READ MORE

This time things are really going to change. On January 9, 2017, the Centers for Medicare & Medicaid Services (“CMS”) released a pre-publication copy of the Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing, with only a few changes, the significant changes they proposed to... READ MORE

Pursuant to its recently issued final rule (“Rule”), CMS is implementing two cardiac-related episode payment models (“EPMs”). One of the EPMs pertains to episodes of care surrounding an acute myocardial infarction (“AMI EPM”); the other EPM pertains to episodes of care surrounding a coronary artery bypass graft (“CABG EPM”). Generally, participation in the AMI... READ MORE

On December 23, 2016, the Department of Health and Human Services, Office of Inspector General (“OIG”) released a report (the “Report”) detailing a case review of inpatient rehabilitation (“rehab”) hospitals.1 The Report indicates that for 39 out of 426 rehab hospital stays reviewed, the patient was unable to participate in and benefit significantly from... READ MORE