Articles and Blogs

The Consolidated Appropriations Act (“Appropriations Act”) that Congress passed in late December 2020 contained a number of provisions that will be of benefit to teaching hospitals. This article is Part 3 of our series providing insight into these CMS changes and more recent statutory changes. Part 1, which addresses resident moonlighting and redocumentation requirements, is…Read More

On Thursday, March 11, 2021, President Biden signed a $1.9 trillion coronavirus relief plan, the American Rescue Plan Act of 2021 (“ARP”), in an effort to speed up the United States’ recovery from the economic and health effects of the COVID-19 pandemic and ongoing recession. Among other things, the ARP extends an additional period of…Read More

The Office of Management and Budget (“OMB”) is requesting comments on the recommendations it has received from the Metropolitan and Micropolitan Statistical Area Standards Review Committee for changes to OMB’s 2010 metropolitan and micropolitan statistical area standards. Among other changes, one proposal would change nearly 150 areas from urban to rural for purposes of the…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. Pointing…Read More

In a new report, the Department of Health and Human Services Office of Inspector General (“OIG”) concluded that hospitals are increasingly billing Medicare for inpatient stays at the highest, most expensive severity level despite many of these stays having only one qualifying diagnosis for payment at the highest severity level and others lasting only a…Read More

In an important development for 340B participating providers (“Covered Entities”), the Department of Health and Human Services (“HHS”) Office of General Counsel (“OGC”) published an Advisory Opinion stating its view that drug manufacturers must honor 340B program discounts under contract pharmacy arrangements. The Advisory Opinion was remarkable in the clarity and forcefulness of HHS’s position…Read More

Noncompliance cited as immediate jeopardy (“IJ”) is one of the most severe survey findings for certified Medicare and Medicaid provider entities. According to the Centers for Medicare & Medicaid Services (“CMS”), IJ “represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury,…Read More