Articles and Blogs

While the COVID-19 public health emergency (“PHE”) has driven significant change throughout health care, some of the more expansive changes relate specifically to the provision of care through telehealth technology (“Virtual Care”). Given the nature and extent of the PHE flexibilities, use of telehealth has skyrocketed. Medicare beneficiaries used telehealth for 43.5% of their... READ MORE

In a recent policy statement, Principal Deputy Inspector General Grimm of the Department of Health and Human Services – Office of Inspector General (“OIG”), highlighted OIG’s support for increased telehealth flexibilities over the last year and expressed the potential for expanding coverage based on the experience of providers and patients during the COVID-19 pandemic.... READ MORE

On December 3, 2020, HHS issued a Fourth Amendment to the Declaration under the Public Readiness and Emergency Preparedness Act (“PREP Act”), which, in part, expands access to certain telehealth services during the COVID-19 public health emergency (“PHE”).  Most notably, this amendment preempts state professional licensure laws with respect to “Covered Countermeasures” that are provided through telehealth... READ MORE

The push for increased telehealth coverage continues during the COVID-19 public health emergency (“PHE”). On October 14, 2020, CMS added 11 new telehealth services available for Medicare reimbursement during the PHE. The newly added services include cardiac and pulmonary rehabilitation services and certain neurostimulator analysis and programming services. Since the beginning of the PHE,... READ MORE

The health care real estate industry has not been immune to the COVID-19 pandemic as evidenced by a lower volume of medical office building sales in the second quarter of 2020. Even so, many current trends in health care real estate existed prior to the COVID-19 outbreak. The outbreak largely amplified, rather than created,... READ MORE

As telehealth expands, so too does the need for hospitals and other health care facilities (collectively “hospitals”) to credential telehealth providers. Commonly asked telehealth credentialing questions include the following: (a) are there particular requirements for credentialing telehealth providers as part of disaster privileging; and (b) must clinical privileging forms be specific to telehealth? Earlier... READ MORE

The COVID-19 state of emergency has spurred unprecedented change in the realm of telehealth. This trend continues – but despite the headlines, there is more work to do. I. CMS Telehealth Proposals CY 2021 PFS On August 3, 2020, CMS posted the proposed Physician Fee Schedule rule (“Proposed Rule”) for CY 2021. The Proposed... READ MORE

Thursday, June 18 Update Note – ​ Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. We believe this is the most up-to-date information available at this time. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. To learn more about... READ MORE

On May 11, 2020, U.S. Citizenship and Immigration Services published a policy memorandum providing temporary flexibility for physicians completing a J-1 waiver service obligation during the COVID-19 pandemic. The policy memorandum addresses the full-time work requirement and telehealth services for these physicians in light of the Public Health Emergency issued in response to the... READ MORE

Wednesday, May 13 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ CMS Launches Toolkit on State Actions to Mitigate COVID-19 in Nursing Homes... READ MORE