Articles and Blogs

Executive Summary On September 23, 2013, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule (“Proposed Rule”) enumerating the details of the pending prospective payment system (“PPS”) for Federally Qualified Health Centers (“FQHCs”).  This Proposed Rule was developed in response to a mandate established in the Patient Protection and Affordable Care... READ MORE

On August 19, 2013, the Centers for Medicare and Medicaid Services (“CMS”) published the acute care hospital and long-term care hospital inpatient prospective payment system final rule for fiscal year 2014 (“Final Rule”).  Under one new provision in the Final Rule, if a Medicare Part A claim for inpatient hospital services is denied because... READ MORE

On September 13, 2013, the Centers for Medicare & Medicaid Services (“CMS”) issued a Medical Learning Network Letter (“Letter”) addressing new guidance for meeting the annual reporting requirements for physician-owned hospitals.1  The Letter affects hospitals with physician ownership and/or investors wishing to rely on the whole hospital or rural provider exception to the Stark... READ MORE

Hall Render is pleased to announce that two of our shareholders, Gerald L. Stovall and Gregg M. Wallander, were recently named the Best Lawyers® 2014 “Lawyers of the Year” (Copyright 2013 by Woodward/White, Inc., of Aiken, SC).  Stovall, who leads the firm’s construction law practice, was named the Best Lawyers 2014 Louisville Construction “Lawyer of... READ MORE

On August 15, 2013, the Internal Revenue Service (“IRS”) published temporary and proposed regulations that provide guidance to tax-exempt hospital organizations regarding the reporting of failures to meet the community health needs assessment (“CHNA”) requirements for any taxable year and the corresponding payment of the $50,000 excise tax (“CHNA Excise Tax Regulations”). READ MORE

On August 15, 2013, the Office of the Inspector General for the Department of Health and Human Services (“OIG”) released a report titled “Most Critical Access Hospitals Would Not Meet the Location Requirements if Required to Re-enroll in Medicare” (“Report”).  If the recommendations in the Report are fully carried out, it could cause nearly two-thirds... READ MORE

On August 14, 2013, the Department of Health and Human Services (“HHS”) announced that it reached a settlement with a not-for-profit New York health plan (“Health Plan”) stemming from alleged violations of the Health Insurance Portability and Accountability Act (“HIPAA”) Privacy and Security Rules. The settlement comes after an HHS Office for Civil Rights... READ MORE

Executive Summary On August 2, 2013, the Centers for Medicare and Medicaid Services (“CMS”) displayed the acute care hospital and long-term care hospital inpatient prospective payment system final rule for fiscal year 2014 (“Final Rule”). In one provision in the Final Rule, CMS aims to provide physicians and hospitals with a clear benchmark for determining... READ MORE

This article is Part III in a five-part series of articles discussing the recently published federal Physician Payment Sunshine Act (“Sunshine Act”). This article focuses on recent updates and resources provided by the Centers for Medicare and Medicaid Services (“CMS”) to assist in Sunshine Act compliance. The first article in the series provided an... READ MORE

Executive Summary On July 1, 2013, the Department of Health and Human Services Office of Inspector General (“OIG”) posted Advisory Opinion 13-07, addressing a proposed arrangement whereby a medical products manufacturer would offer tiered rebates to customers on a combination of products, some of which are reimbursable under the Federal health care programs (“Proposed... READ MORE