Articles and Blogs

On August 23, 2011, CMS invited health care providers to apply to help test and develop four different models of bundled payments. This Initiative is part of CMS’ overall effort under the Affordable Care Act to better coordinate care among providers. Unlike the criticism CMS received regarding the complexity of the Shared Savings Program,... READ MORE

There has been a significant development in how the EEOC views No-Fault Attendance Policies that fail to consider whether the reason for an absence was due to a disability.  Employers that don’t consider disability-caused absences in applying discipline can be in jeopardy under the ADA for failing to reasonably accommodate the employee’s disability by... READ MORE

The Department of Health and Human Services (“HHS”) in coordination with the Office of Science and Technology Policy (“OSTP”) will reportedly announce on September 1, 2011, an extension to the comment period for an advanced notice of proposed rulemaking (“ANPRM”) in the Federal Register.  The ANPRM was published in the Federal Register on July... READ MORE

On August 23, 2011, the U.S. Department of Health and Human Services (“HHS”) issued the updated Final Rule on financial conflict of interest regulations for institutions applying for or receiving Public Health Service (“PHS”) funding, including from the National Institutes of Health (“NIH”).  The rule amends the 1995 PHS regulations “Responsibility of Applicants for... READ MORE

The Centers for Medicare & Medicaid Services (CMS) released its highly anticipated final rule earlier this summer1 implementing a Medicare Value-Based Purchasing Program (VBP) as required under the Patient Protection and Affordable Care Act (ACA).  VBP is just one of the many initiatives mandated by Congress in an attempt to forge a closer link... READ MORE

On August 23, 2011, the U.S. Department of Health and Human Services (“HHS”) issued the updated Final Rule on financial conflict of interest regulations for institutions applying for or receiving Public Health Service (“PHS”) funding, including from the National Institutes of Health (“NIH”).  The rule amends the 1995 PHS regulations “Responsibility of Applicants for... READ MORE

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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