Articles and Blogs

In recent years, many health care providers have dedicated substantial resources to community health or initiatives targeted at improving social determinants of health. As outlined in a recent Hall Render article, the Tax Cuts and Jobs Act of 2017 gives health care providers a mechanism for furthering such goals while realizing significant tax savings by…Read More

A federal district court in Connecticut recently applied the Supreme Court’s favorable opinion in the Allina case (which we previously wrote about here), compelling the Secretary to adhere to notice-and-comment rulemaking of Medicare policy when it affects providers’ eligibility, benefits or payment. Additionally, CMS cannot use a preclusion statute to avoid challenges for which it did not follow…Read More

It is no surprise that state and federal legislators are taking action to address the issue of unexpected medical bills, otherwise known in the health care industry as “surprise billing.” Surprise billing generally occurs when a patient receives care at an out-of-network facility (often emergency care) or from an out-of-network provider at an in-network facility…Read More

In late July 2019, CMS issued claims processing requirements for the educational and operations testing period for appropriate use criteria (“AUC”) related claims for advanced diagnostic imaging. Advanced imaging includes CT, PET, nuclear medicine, and MRI. The testing period begins January 1, 2020. The CMS Program Transmittal can be found here. Background The Protecting Access…Read More

On June 14, 2019, the U.S. Department of Health and Human Services (“HHS”) published in the Federal Register a proposal to revise certain civil rights anti-discrimination regulations implementing and enforcing Section 1557 of the Affordable Care Act (“ACA”) (“Section 1557 Rule”) that HHS believes are inconsistent with pre-existing civil rights statutes and likely unlawful (“Proposed…Read More

On August 16, 2019, the Federal Fiscal Year (“FFY”) 2020 Medicare Inpatient Prospective Payment System (“IPPS”) final rule (“IPPS Final Rule”) was published in the Federal Register. In the IPPS Final Rule, the Centers for Medicare & Medicaid Services (“CMS”) finalized several changes announced in the proposed rule, including several changes to address disparities between high and…Read More

On July 11, 2019, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) released the new Grant Self-Disclosure Program Guidance (“Grant Guidance”) for HHS grant recipients and subrecipients. Through the Grant Guidance, OIG provides new self-reporting options for HHS grant recipients and subrecipients who determine that they have…Read More