Articles and Blogs


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

Tags: , , , , ,

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


CMS Seeks Comments on Dispute Resolution and Corrections Process for Sunshine Act Payments


Posted on May 9, 2014 in Health Law News

Published by: Hall Render

According to a Federal Register notice published on May 5, physicians and teaching hospitals will soon be able to register with the Centers for Medicare and Medicaid Services (“CMS”) to receive notices from and access to CMS’s Open Payments database.  The Open Payments database will contain information about payments and other transfers of value that... READ MORE

Tags: , ,

2-Midnight Rule 0.2% IPPS Offset Group Appeal


Posted on January 17, 2014 in Health Law News

Published by: Hall Render

Executive Summary Hall, Render, Killian, Heath & Lyman is forming a group appeal relating to a negative payment adjustment made by CMS and implemented in the Federal Fiscal Year (“FFY”) 2014 Final Inpatient Prospective Payment System (“IPPS”) rule published August 19, 2013.  By this rule, CMS decreased IPPS payments to hospitals by 0.2% to offset... READ MORE


Preliminary Impact of Government Shutdown on LTC Providers–UPDATE


Posted on October 1, 2013 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Centers for Medicare & Medicaid Services (“CMS”) issued a Survey & Certification Memo (“S&C Letter”) to state agencies detailing the result of the governmental shutdown on long-term care providers as it relates to surveys.  As of this writing, the S&C Letter has not been published or otherwise made publicly available, and the below... READ MORE

Tags: , , , , , , ,

CMS Delays Full Implementation of the 2-Midnight Rule Until January 1, 2014


Posted on October 1, 2013 in Health Law News

Published by: Hall Render

On August 19, 2013, the Centers for Medicare and Medicaid Services (“CMS”) published in the Federal Register the 2014 acute care hospital and long-term care hospital inpatient prospective payment system final rule (“Final Rule”) effective on October 1, 2013.  As part of the Final Rule, CMS formulated a “2-midnight presumption” and a “2-midnight benchmark”... READ MORE