Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”) could revoke or deny a provider’s or supplier’s Medicare enrollment if it determines that any of its affiliations pose an “undue risk” under a Final Rule announced on September 5, 2019 (“Enrollment Rule”). Also under the Enrollment Rule, providers and suppliers (“Providers”) selected by CMS will... READ MORE

CMS recently posted reminders regarding the availability of MIPS final scores and the deadline to request review if an error has been made: “If you participated in the Merit-based Incentive Payment System (MIPS) in 2018, your performance feedback, which includes your MIPS final score and payment adjustment factor(s), are available for review on the Quality... READ MORE

In 2014, Congress enacted the Protecting Access to Medicare Act (“PAMA”), changing the landscape of Medicare reimbursement for lab services. PAMA required the Centers for Medicare & Medicaid Services (“CMS”) to establish a single, national Clinical Laboratory Fee Schedule (“CLFS”) based on current charges in the private health care market. Below, we provide background... READ MORE

On July 18, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published final regulations titled “Medicare and Medicaid Programs; Revision of Requirements for Long-Term Care Facilities: Arbitration Agreements” (“Final Regulations”) to Part 483 to Title 42 of the Code of Federal Regulations the Requirements for States and Long-Term Care Facilities. The Final Regulations... READ MORE

In the recently issued Physician Fee Schedule Proposed Rule for Calendar Year 2020, the Centers for Medicare & Medicaid Services (“CMS”) proposed several revisions to its Stark Law advisory opinion process. These proposed revisions follow CMS’s receipt of several stakeholder comments in response to its Request for Information Regarding the Physician Self-Referral Law published... READ MORE

On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released its proposed rule for Calendar Year (“CY”) 2020 Hospital Outpatient Prospective Payment System (“Proposed Rule”). Among many other changes, CMS proposed three key payment policy updates impacting hospital outpatient departments, including: (1) lowering the supervision standard for hospital outpatient therapeutic services... READ MORE

Effective July 1, 2019, The Joint Commission (“TJC”) implemented new and revised requirements regarding suicide prevention for all TJC-accredited hospitals and behavioral health entities. The seven new and revised requirements, part of TJC’s elements of performance (“EPs”) under National Patient Safety Goal (“NPSG”) 15.01.01, are designed to improve quality and safety of care for... READ MORE

On July 16, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released a pre-publication copy of the revisions (“Proposed Rule”) to Part 483 to Title 42 of the Code of Federal Regulations the Requirements for States and Long-Term Care Facilities (“RoPs”). CMS stated that it identified a number of existing skilled nursing facility... READ MORE

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). To view other articles in this series, click here. Beginning on November 28,... READ MORE

Thanks to a final rule issued by the Centers for Medicare & Medicaid Services (“CMS”) this spring, Medicare Advantage (“MA”) plans will now be able to offer additional telehealth benefits to enrollees starting in 2020. Historically, MA plans have been able to offer more telehealth services compared to Original Medicare as part of their... READ MORE