Articles and Blogs

reimbursement

Policy Updates to Compliance Program Needed When Creating “COVID-19 Ready” Skilled Nursing Facilities and Units

[05/18/20]

Posted on May 18, 2020 in COVID-19 Daily Updates, Long-Term Care, Home Health & Hospice

Published by: Hall Render

States like Indiana, Connecticut and Maine are offering to pay nursing homes a higher per diem for COVID-19 presumptive residents or a higher percentage reimbursement rate if a nursing home qualifies as a “COVID-19 ready” facility, as discussed in our recent article here. As nursing homes assess, plan for and take actions to qualify... READ MORE

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Did the Ground Just Shift? CMS Proposes Changes to Hospital Wage Index Areas

[05/13/20]

Posted on May 13, 2020 in COVID-19 Daily Updates, Health Law News

Published by: Hall Render

On May 11, 2020, CMS released the 2021 Inpatient Prospective Payment System (“IPPS”) Proposed Rule (“Proposed Rule”). Among other changes in the Proposed Rule, CMS is adopting updated labor market area delineations to take effect on October 1, 2020. Hospitals should review whether they are in a county that is affected by the updated... READ MORE

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CMS Flexibilities for Billing Hospital Outpatient Therapeutic Services During the COVID-19 Public Health Emergency

[05/05/20]

Posted on May 5, 2020 in Health Law News

Published by: Hall Render

On April 30, 2020, CMS published guidance in a second Interim Final Rule (“IFR”) addressing regulatory flexibilities available to hospitals to bill for hospital/critical access hospital outpatient therapeutic services on the UB-04 when such services are furnished in a temporary expansion location (including a beneficiary’s home) during the COVID-19 public health emergency (“PHE”). This... READ MORE

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HHS Outlines Framework for Reimbursing Hospitals and Providers for COVID-19 Testing and Treatment Provided to Uninsured Patients

[04/23/20]

Posted on April 23, 2020 in Health Law News

Published by: Hall Render

On April 23, the Department of Health and Human Services (“HHS”) outlined the basic framework for a new program to reimburse hospitals and other providers and suppliers for services provided to uninsured COVID-19 patients (for purposes of this article we refer to both providers and suppliers as “providers”). The framework for the program is... READ MORE

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Providers May Set Reimbursement Rates with Out-Of-Network Payors for COVID-19 Testing by Posting Rate to Website

[04/22/20]

Posted on April 22, 2020 in Health Law News

Published by: Hall Render

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which became law on March 27, 2020, requires all providers of COVID-19 diagnostic testing to publish on their public websites the cash price for such testing during the declared emergency.[1] Doing so also allows health care providers to set a reimbursement rate with out-of-network... READ MORE

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

[03/27/20]

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

[02/28/20]

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

[10/25/19]

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

[10/08/19]

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

[09/03/19]

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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