Articles and Blogs

In its latest capital markets update, H2C noted that July nonprofit hospital bond issuance was down 57% year-over-year and down 52% year-to-date (compared to January through June 2022). CMS issued a final rule that will increase payments to SNFs by 4%, or $1.4B, starting in 2024. CMS described the increase as a “parity adjustment recalibration,”…Read More

A new Arizona law imposes several written disclosure requirements that Arizona health facilities must provide to emergency responders when transferring an individual into their care. The new Arizona law (“Arizona Assisted Living Law”) also calls for several written disclosure requirements that Arizona hospitals must provide to an assisted living facility when transferring and discharging an individual into…Read More

The Fifth Circuit Court of Appeals (the “Fifth Circuit”) rendered a significant decision recently in Braidwood Management, Inc. v. Equal Employment Opportunity Commission. This decision has garnered attention and sparked discussions due to its potential implications for religious freedom, employment law and the rights of individuals in the workplace. Background In Braidwood, the plaintiff was a for-profit…Read More

Starting on August 1, 2023, Medicare validation edits will be activated to require service location addresses on the UB-04 hospital claim form to match exactly with the service location enrolled in Medicare’s Provider Enrollment, Chain, and Ownership System (“PECOS”). Background In a previous article, we reported on the Center for Medicare & Medicaid Services (“CMS”)…Read More

The Biden Administration proposed a new rule to strengthen mental health parity under health care plans. The proposed rule, if finalized, would require health plans to provide members with equal access to behavioral health services. The rule also requires health plans to study the impact of plan restrictions on access to mental health and substance…Read More

In 2022, the Biden administration announced an initiative to increase the transparency of corporate and private equity ownership and operation of nursing homes. Recently, the Centers for Medicare & Medicaid Services (“CMS”) announced that it would include ownership and operatorship affiliation information on its Nursing Home Care Compare website and that it would publish combined…Read More

On December 14, 2022, the Office of Inspector General (“OIG”) issued an advisory opinion which approved a hospital program (“Arrangement”) to provide advanced practice provider (“APP”) support for inpatients being cared for by primary care physicians (“Participating Physicians”). Several months later, in May 2023, the Department of Justice (“DOJ”) reached a settlement of $29,744,065 with…Read More

A new mandatory bundled payment model is likely on its way in 2026, and the Center for Medicare & Medicaid Innovation (“CMMI”) is seeking input on how to structure the model to work for existing population-based models, including accountable care organizations (“ACOs”). On July 18, 2023, CMMI released a Request for Information (“RFI”) on a…Read More