Articles and Blogs

Yesterday, the American Hospital Association (“AHA”) submitted comments to CMS regarding the proposed FY 2015 inpatient prospective payment system (“PPS”) rule.  Topics addressed by AHA include: READ MORE

Executive Summary The Department of Health & Human Services Office of Inspector General (“OIG”) recently released a Supplemental Special Advisory Bulletin (“Supplemental Bulletin”) on the potential fraud and abuse implications of prescription drug patient assistance programs (“PAPs”).  The Bulletin updates OIG’s 2005 Special Advisory Bulletin (“2005 Bulletin”) on PAPs for Medicare Part D enrollees... READ MORE

Executive Summary On May 23, 2014, the Centers for Medicare and Medicaid Services (“CMS”) published a final rule addressing various changes to the Medicare Advantage (Part C) and Medicare Prescription Drug Benefit (Part D) Programs (“Final Rule”). Among other changes, the Final Rule enumerated new Medicare enrollment or opt-out requirements for prescribers of Part D covered... READ MORE

Executive Summary CMS issued a proposed rule that, if finalized, may make it harder for hospitals to file cost report-based appeals or possibly reimbursement-related appeals from the Federal Register.  Hall Render has already submitted comments to CMS on behalf of its client hospitals, but hospitals are welcomed and encouraged to submit their own comments to... READ MORE

On Wednesday, May 21, 2014, in a letter to American Hospital Association President Richard Umbdenstock, Health and Human Services (“HHS”) Secretary Kathleen Sebelius confirmed that private, not-for-profit foundations can use properly structured premium support programs to make premium payments to Qualified Health Plans (“QHPs”) on behalf of QHP enrollees.1  In this latest guidance on the... READ MORE

Hospital Physician Practice Acquisitions: How Electronic Medical Records Impact READ MORE

CMS recently announced the creation of a new role in the medical review process—a Provider Relations Coordinator.  The announcement is below and can be found on the CMS website. READ MORE

Since the enactment of the Jumpstart Our Business Startups Act (cleverly referred to by Congress as the “JOBS Act”) last fall, much has been written regarding its impact on private placements of debt and equity securities.  Most of the reports, briefings and articles have been accurate, but few have been practical.  We find one provision... READ MORE

Recently, the Department of Health & Human Services Office of Inspector General (“OIG”) issued a Notice of Termination1 of Advisory Opinion 11-18, which was issued December 7, 2011,2 and rejected a similar proposal in Advisory Opinion 14-03.3 READ MORE

Recently, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule to update fire safety standards for certain types of facilities (“Proposed Rule”).  In the Proposed Rule, CMS proposes to adopt the 2012 Life Safety Code (“LSC”), with certain exceptions discussed below, to replace the 2000 version currently required by the Conditions of... READ MORE