Articles and Blogs

On May 2, 2012, the National Association of Bond Lawyers (“NABL”) submitted suggested clarifications and changes to Revenue Procedure 97-13 (“Rev. Proc. 97-13”) to the Internal Revenue Service (the “IRS”).  These comments were prepared by a subcommittee of NABL’s Tax Committee, which subcommittee included Kendall Schnurpel of Hall Render’s Health Care and Public Finance... READ MORE

On May 10, 2012, the Centers for Medicare and Medicaid Services (“CMS”) released an advance copy of a final rule (“Final Rule”) revising several critical access hospital (“CAH”) Medicare conditions of participation (“CoPs”).  These changes, together with a number of changes to the hospital CoPs, will benefit hospitals of both types by allowing for... READ MORE

Overview CMS has released a final rule (“Final Rule”) revising the hospital and critical access hospital (“CAH”) Medicare conditions of participation (“CoPs”).  This Final Rule implements President Obama’s Executive Order 13563 calling for removal or modification of obsolete or unnecessary regulations on hospitals and CAHs.  Indeed, the Final Rule reduces burdens, provides flexibility and... READ MORE

Background Throughout the existence of the Medicare Part D program, the Office of Inspector General (“OIG”) has issued several reports concerning the vulnerability of the Medicare Part D program in regards to its potential for fraud and abuse.  On May 9, 2012, the OIG released a report identifying eight questionable billing practices of retail pharmacies throughout... READ MORE

Wisconsin Physicians Service (WPS) will soon begin to serve as the Medicare Administrative Contractor (MAC) for Jurisdiction 8, which includes the states of Indiana and Michigan.  According to listserve communications, Indiana Part A providers and Michigan Part A providers will transition to WPS effective July 23, 2012.  Indiana Part B suppliers will transition to... READ MORE

This installment of Hall Render’s Health Law Broadcast series on health care reform is designed to provide you with the insight, analysis and practical suggestions with respect to the various reform initiatives that will affect your organization. On May 7, 2012, the Centers for Medicare and Medicaid Services (“CMS”) published a final rule (“Final... READ MORE

Disproportionate Share Hospital (DSH) Routine Use Data is now available through CMS.  In our Update indicating new SSI Ratios for Medicare DSH were published on March 16, 2012 for Fiscal Years (FYs) 2006 – 2009, we recommended that Hospitals obtain their DSH Routine Use Data in order to have the underlying data used by... READ MORE

In an open letter published this week, Sen. Max Baucus (D-MT) and Sen. Orin Hatch (R-UT), the Chairman and Ranking Member of the Senate Finance Committee, called on the health care industry to provide solutions and suggestions on how to fight waste, fraud and abuse in the Medicare and Medicaid programs.  The full letter... READ MORE

Part 2 of 2 If it survives the current legal challenge in the U.S. Supreme Court, the mandatory coverage aspect of the Affordable Care Act (“ACA”) will not take effect until 2014.  This timing has the effect of making hospitals tentative about capital deployment in general and for real estate in particular. Besides timing... READ MORE

On April 26, 2012, Corporate Communications at National Government Services, Inc. issued the following statement: “Recently, the Region B Medicare Recovery Audit Contractor (RAC), CGI Federal, announced that ‘Based on a technical error discovered, CGI finds the Rituximab edit, an automated take back, was disallowed in error. Therefore, CGI reverses the original decision on... READ MORE