Articles and Blogs

Executive Summary. On October 24, 2011, the Centers for Medicare and Medicaid Services (“CMS”) released a proposed rule (“Proposed Rule”) to revise a number of hospital and critical access hospital (“CAH”) conditions of participation (“CoPs”).  The revisions would implement the President’s Executive Order 13563 calling for the removal or revision of obsolete, duplicative or... 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.  “WE HAVE MADE SIGNIFICANT MODIFICATIONS TO REDUCE THE BURDEN AND COST FOR PARTICIPATING ACOs”1 Background Introduction.  On... READ MORE

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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.  The very much anticipated final regulations for the new Shared Savings Program under Section 3022 of the Affordable... READ MORE

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On October 6, 2011, the Provider Reimbursement Review Board released Decision No. 2012-D1 ruling on two issues related to proper calculation of “total paid hours” when calculating the wage index for hospitals in Cincinnati and rural Iowa.  Both issues related to hour recorded as paid by the hospitals but not actually worked by employees. ... READ MORE

On October 5, 2011, the National Labor Relations Board announced that it has postponed the implementation date for its new Notice Posting Rule by more than two months in order to allow for “enhanced education and outreach to employers,” particularly those who operate small and medium sized businesses.  The posting requirement for most private... READ MORE

Executive Summary On October 5, 2011, the Office of Inspector General (“OIG”) published its proposed Work Plan for Fiscal Year (“FY”) 2012 (“Plan”).  The Plan, which is published annually and describes the OIG’s new and ongoing audit and enforcement priorities for the upcoming year, is helpful in identifying corporate compliance risk areas and providing... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) released a final rule modifying the Medicare Electronic Prescribing Incentive Program (“eRx Program”) on August 31, 2011.  The eRx Program provides an incentive to “Eligible Professionals” who adopt e-prescribing technology beginning in 2009 and a payment adjustment (or penalty) for late adopters beginning in 2012.  The... READ MORE

A good reminder for leases between health care entities and physician groups is that under the Stark regulations, the space rented is reasonable and necessary for the legitimate business purposes of the lease and is used exclusively by the lessee (during such times when the lessee is using the space) and is not shared... READ MORE