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In an effort to reduce fraud, waste and abuse of the Medicare program, the Affordable Care Act (section 6401A) implemented new risk screening criteria that require revalidation of enrollment by providers and suppliers who enrolled in the Medicare program prior to Friday, March 25, 2011.  Under the new screening criteria, newly-enrolling and revalidating providers... READ MORE

As stated in the Health Law News article, for certain types of non-IPPS hospitals the statutory payment window is only one (1) day preceding the patient’s admission.  To clarify, those non-IPPS hospitals are psychiatric hospitals and units, inpatient rehabilitation hospitals and units, long-term care hospitals, children’s hospitals and cancer hospitals.  Critical access hospitals are... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) published the FFY 2012 Final Rule for the Inpatient Rehabilitation Facility (“IRF”) Prospective Payment System (“PPS”) in the Federal Register on August 5, 2011. The Final Rule provides for a 2.2% increase to IRF payment rates for FFY 2012 and implements other adjustments, including updates to... READ MORE

On August 1, 2011, the Centers for Medicare and Medicaid Services (CMS) issued its Fiscal Year (FY) 2012 Inpatient Prospective Payment System (IPPS) Final Rule clarifying which outpatient services are required to be bundled with inpatient services in submission of Medicare claims.  This billing policy is commonly known as the 3-Day Window Rule and... READ MORE

On August 1, 2011, the Centers for Medicare & Medicaid Services (CMS) published the Federal Fiscal Year (FFY) 2012 Final Rule for Inpatient Prospective Payment System (IPPS) and the Long-term Care Hospital Prospective Payment System on its website. For FFY 2012, Providers will receive a net total increase of 1% to the standardized amount.  This... READ MORE

SUMMARY On June 24, 2011, the United States Court of Appeals for the District of Columbia released a decision in Auburn Regional Medical Center v. Sebelius.  The decision reversed an unfavorable district court decision ruling that statutory deadlines to file appeals with the Provider Reimbursement Review Board (PRRB) were not subject to the doctrine... READ MORE

Late last week, a wide-ranging initiative to update federal human research protection regulations was announced by the U.S. Department of Health and Human Services (HHS) and the White House Office for Science & Technology Policy (OSTP) through issuance of an Advance Notice of Proposed Rulemaking (ANPRM), which aims to catch the regulations up to... READ MORE

On May 4, 2011, we issued a bulletin alerting hospital clients that the Office of Inspector General (“OIG”) Office of Audit Services was in the process of sending numerous Contact Letters to hospitals across the country in an effort to verify their levels of compliance with Medicare billing requirements.  As part of this audit,... READ MORE

On July 5, 2011, the Department of Defense (“DoD”) published a Proposed Rule (“Proposed Rule”) notifying the public of DoD’s pending implementation of a revised TRICARE payment methodology for Sole Community Hospital (“SCH”) inpatients.  This revised payment methodology is an important development since, once it is fully phased in, it will likely result in... READ MORE