Articles and Blogs


Latest Stimulus Bill Includes Over $100 Billion in Health Care Industry Relief: Providers Should Start Preparing Now


Posted on March 27, 2020 in Health Law News

Published by: Hall Render

On March 25, 2020, the Senate passed the Coronavirus Aid, Relief, and Economic Security Act (H.R. 748) (“CARES Act” or “Act”). The CARES Act contains numerous provisions aimed at the response to the Coronavirus or COVID-19 pandemic, including $100 billion in reimbursement to hospitals and other health care entities for COVID-19-related expenses and lost... READ MORE

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Deadlines Matter in Wage Index Case


Posted on February 28, 2020 in Health Law News

Published by: Hall Render

On February 11, 2020, the U.S. Court of Appeals for the District of Columbia (D.C.) Circuit upheld the decision of a lower court granting summary judgment in favor of the Secretary of the Department of Health and Human Services (“HHS”) in a wage index calculation Medicare reimbursement case. The Court held that the Secretary’s... READ MORE

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MAC Attacks on the Rise for Allied Health Education Programs


Posted on October 25, 2019 in Health Law News

Published by: Hall Render

Recently, hospitals operating nursing and other allied health (“N&AH”) education programs have experienced increased scrutiny during Medicare Administrative Contractor (“MAC”) audits concerning their receipt of pass-through cost reimbursement. In many instances, MACs have begun disallowing or reclassifying costs that N&AH education programs received without issue for many years. Oftentimes the MACs are citing new... READ MORE

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Next Up for Patient Driven Payment Model? Key Legal and Compliance Considerations Ahead for PDPM


Posted on October 8, 2019 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

With the October 1, 2019 beginning date now past for Patient Driven Payment Model (“PDPM”), the new skilled nursing case-mix classification mode under the Skilled Nursing Facility Prospective Payment System (“SNF PPS”) for classifying SNF patients in a covered Medicare Part A stay, providers need to consider several key legal and compliance program considerations... READ MORE

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Reminder: Many Hospitals Will Be Required to Report Lab Price Data as Part of PAMA Changes


Posted on September 3, 2019 in Health Law News

Published by: Hall Render

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

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Hospital Improvements for Payment: Opportunity to Comment


Posted on November 21, 2014 in Health Law News

Published by: Hall Render

On Wednesday, November 19, the House Ways and Means Subcommittee on Health released draft legislation intended to improve hospital issues in the Medicare system.  The legislation addresses Medicare’s controversial “two-midnight” rule, short inpatient stays, outpatient observation status, the RAC audit program and the appeals process. While the legislative draft is subject to change following... READ MORE


Indiana Medicaid to Reimburse Home Health Agencies for Certain Telehealth Services


Posted on October 31, 2014 in Long-Term Care, Home Health & Hospice

Written by: Taylor, Allison L.

Senate Enrolled Act 554 from the 2013 legislative session set the stage for an upcoming change in Medicaid policy that will provide reimbursement for certain telehealth services provided by Home Health Agencies (“HHAs”).  The Indiana Health Coverage Programs (“IHCP”) released Bulletin BT201454 earlier this week outlining the policy change that will cover an HHA’s remote monitoring of data... READ MORE

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The IOM Recommends That the Current GME Reimbursement System Is Overhauled – Are You Prepared to Weather the Storm?


Posted on October 30, 2014 in Health Law News

Published by: Hall Render

The recent report by the Institute of Medicine on the United States graduate medical education system, Graduate Medical Education That Meets the Nation’s Health Needs1 (“IOM Report”), advances many structure reform themes that have appeared in other assessments in recent years.  However, it goes much further.  The IOM Report calls for fundamental changes to... READ MORE


CMS Did Not Finalize Proposed Changes to Cost Reporting Requirements and PRRB Appeals


Posted on August 6, 2014 in Health Law News

Published by: Hall Render

Executive Summary In the FY 2015 Inpatient PPS Final Rule, CMS did not finalize problematic changes to the cost reporting requirements that the agency introduced in the proposed rule.  On behalf of clients of Hall Render and Baker Healthcare Consulting, Hall Render previously opposed the proposed rule in comments to CMS and consultations with... READ MORE


DSH Medicaid Eligible Days Documentation


Posted on May 28, 2014 in Health Law News

Published by: Hall Render

Executive Summary On Friday, May 23, 2014, the Provider Reimbursement Review Board (“PRRB”) released an alert directed at hospitals with pending appeals on the issue of allowable “Medicaid Eligible” days in the calculation of hospitals’ disproportionate share (“DSH”) payments.  Hospitals with Medicaid eligible day appeals have 60 days to provide additional information to the PRRB. ... READ MORE