Articles and Blogs

This week, the Centers for Medicare & Medicaid Services (“CMS”) announced that it is extending participation in the Bundled Payments for Care Improvement (“BPCI”) initiative through September 30, 2018. Awardees in the BPCI initiative can now extend their participation in Models 2, 3 and 4 until that date. Originally, awardees that began in October... READ MORE

In the proposed Inpatient Prospective Payment System (“IPPS”) rule for FFY 2017, hospitals will benefit from the restoration of payments CMS has taken away from hospitals since FFY 2014, related to implementation of the Two-Midnight Rule that redefined the definition of inpatient admissions. Not only will there be no 0.2 percent decrease in IPPS payments... READ MORE

On April 15, 2016, the Food and Drug Administration (“FDA”) issued three important draft guidance documents that clarify the standards under Sections 503A and 503B of the federal Food Drug & Cosmetic Act (“the Act”) applicable to compounding activities carried out by prescription drug compounders. These compounders include hospital pharmacies, non-hospital pharmacies (including retail... READ MORE

Secondary Payer Refunds, Overpayments and Obligations CMS’s new rule regarding the reporting and returning of Medicare overpayments (effective March 14, 2016) makes clear that secondary payer refunds owed by health care providers to Medicare may become overpayments for purposes of the new rule. Without sufficient oversight, such overpayments may expose a health care provider to... READ MORE

Executive Summary April 16, 2016 is National Healthcare Decisions Day. The goal of the day is to encourage Americans to think and talk about their health care goals and communicate their health care decisions by executing advance health care directives. Background Studies indicate that most Americans have not executed documents that name a health... READ MORE

On April 11, 2016, the Centers for Medicare & Medicaid Services (“CMS”) announced a new model for the way Medicare pays many primary care physicians. The Comprehensive Primary Care Plus (“CPC+”) model aims to enhance primary care through care redesign. CPC+ will include two primary care practice tracks with incrementally advanced care delivery requirements... READ MORE

CMS posted a notice on its website inviting stakeholders to submit questions and/or scenarios to CMS regarding implementation of the Budget Act provision impacting OPPS coverage for off-campus provider-based departments. The full notice, which can be found here, follows. Note Regarding Implementation of Section 603 of the Bipartisan Budget Act of 2015 CMS will... READ MORE

Indiana health care providers involved in prenatal care need to be aware of recent Senate Bill 186 that was signed into law by Governor Mike Pence on March 21, 2016. The new law amends the Indiana Code on health professions standards of practice to clarify that licensed physicians, physician assistants, midwives and advanced practice... READ MORE

On March 18, 2016, the Centers for Disease Control and Prevention (“CDC”) issued a Guideline for Prescribing Opioids for Chronic Pain (i.e., pain lasting longer than three months or past the time of normal tissue healing) geared toward primary care physicians (“CDC Recommendations”). The CDC Recommendations do not apply to prescribing practices for active... READ MORE

On March 29, 2016, President Obama will announce additional private and public sector actions to fight the national opioid epidemic. The president, who is speaking this afternoon at the National Rx Drug Abuse & Heroin Summit in Atlanta, Georgia, will announce the following health care-related administrative actions being taken to combat the opioid epidemic that... READ MORE