Articles and Blogs

Executive Summary On December 18, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released a draft Quality Measure Development Plan (“Draft Plan”) to serve as a strategic framework for the future of clinician quality measure development for the transition to new Merit-Based Incentive Payment System (“MIPS”) and alternative payment models (“APMs”).1 The Draft Plan…Read More

Executive Summary The Centers for Medicare & Medicaid Services (“CMS”) issued Change Request 9271 on January 4, 2016, which informs providers to waive the deductible and coinsurance for Advanced Care Planning (“ACP”) when furnished as an optional element of an Annual Wellness Visit (“AWV”). When ACP services are performed separately from a covered AWV, the…Read More

As the health care payment and delivery system continues to evolve, Hall Render attorneys are committed to providing practical counsel and insight to health care providers. Below is a compilation of key developments from 2015 that will continue to impact the health care industry in 2016. As the new year begins, our attorneys will continue to…Read More

ACA Repeal Heads to President’s Desk On January 6, the House voted 240-181 to send an Affordable Care Act (“ACA”) repeal bill (H.R. 3762) to the president’s desk through the expedited budget reconciliation process that does not require 60 votes to pass the Senate.  While the White House has said Obama will quickly veto the…Read More

Hall Render has become aware that the Department of Justice Office of Special Counsel for Immigration-Related Unfair Employment Practices (“OSC”) is currently investigating numerous hospitals across the country on the grounds that the hospitals’ advertisements for podiatric residency positions may be in violation of the Immigration and Nationality Act (“INA”). OSC, which is responsible for…Read More

Since the September 8, 2015 publication of the notice of proposed rulemaking (“NPRM”) proposing several significant changes to the Federal Policy for the Protection of Human Subjects (the “Common Rule”) in the Federal Register, the Department of Health and Human Services (“HHS”) Office of Human Research Protections (“OHRP”) has received sharp criticism from many in…Read More

UPDATE – January 19, 2016: Although both houses of the New Jersey legislature passed the measure mentioned in this post, New Jersey Governor Chris Christie subsequently pocket vetoed the measure. Legislators at the state and local levels are reportedly continuing their efforts to craft a legislative solution to clarify hospital property tax exemptions in New…Read More

Last year, as part of the CY 2015 Outpatient Prospective Payment System (“OPPS”) Final Rule (“Final Rule”), the Centers for Medicare & Medicaid Services (“CMS”) finalized a policy implementing new coding and billing requirements related to services furnished in off-campus provider-based departments of hospitals.  These new requirements, which are discussed in more detail below, involve…Read More

Congress Passes Spending Bill On December 18, the House and Senate overwhelmingly passed the omnibus spending bill.  Prior to midnight on December 15, the House revealed the details of the FY16 omnibus appropriations package, which funds the federal agencies and programs through September 30, 2016.  The White House has indicated it intends to sign the…Read More

Executive Summary Recently, the U.S. Department of Justice (“DOJ”) announced a $256 million settlement with one of the nation’s largest urine drug testing (“UDT”) laboratories (“Lab”).  According to a False Claims Act (“FCA”) complaint in intervention filed by the U.S., from January 1, 2008 through May 20, 2015, the Lab “systematically” billed the federal health…Read More