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Articles by Caroline Reigart
[Ongoing Program] Setting Up Successful Vendor Arrangements Under the Medicare Provider-Based Rule - February 10th, 12:30 pm - 1:30 pm ET | JD Supra Original
February 10th, 2022 12:30 PM - 1:30 PM ET Demystifying the Regulatory Framework for Vendor Arrangements with Hospitals – A Three Part Series Hospital and health systems rely on vendors and other partners to provide vital services that support patient care, efficient operations and smooth administrative functions. However, the regulations governing different types of arrangements with hospitals are complex and can often present unexpected pitfalls.
Hospital Reimbursement Opportunity Remains After CMS Decides Not to Finalize DSH Payment Calculation Changes | JD Supra
On December 17, 2021, the Centers for Medicare & Medicaid Services (CMS) released the fiscal year (FY) 2022 inpatient prospective payment system (IPPS) final rule. In light of the significant volume of comments, CMS declined to adopt any modifications to the current disproportionate share hospital (DSH) payment regulations.
CMS Leaves Hospitals Guessing on Expectations for Compliant Co-Location Arrangements | JD Supra
On November 12, 2021, the Centers for Medicare and Medicaid Services (CMS) released an updated version of its Quality, Safety and Oversight Group memorandum, QSO-19-13-Hospital, containing much-anticipated final guidance on how state surveyors are to evaluate hospital compliance with Medicare hospital conditions of participation (CoPs) in connection with hospital co-location arrangements with other hospitals and “healthcare providers.” Co-location arrangements refer to any arrangement under...
CMS Finalizes Changes to Clarify Physician and NPP “Split (or Shared)” Billing Policy | JD Supra
On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) final rule which, among other policy and regulatory changes, finalized regulations codifying CMS requirements for billing for “split (or shared)” evaluation and management (E/M) visits under the MPFS. Split (or shared) visits are E/M visits provided in part by both physician and non-physician practitioners (NPPs) and are now defined at 42 CFR § 415.140.
CMS Seeks Comments on Requirements for Rural Emergency Hospitals as a New Medicare Provider Category | JD Supra
Background Under current Medicare program rules, Medicare does not recognize “freestanding emergency departments” or other non-hospital providers of emergency department services. Medicare will only pay for these services at facilities that meet the Medicare definition of “hospital,” which requires the provision of inpatient services, among other requirements that are often difficult for low-volume facilities to meet.
CMS Proposes New Regulation to Clarify Physician and NPP “Split (or Shared)” Billing Policy | JD Supra
On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) proposed rule (Proposed Rule). The Proposed Rule sets forth CMS’ plans to revise Medicare payment policies and rates for the upcoming year. In the CY 2022 Proposed Rule, CMS provides its proposal for regulations codifying its long-standing guidance on billing for “split (or shared)” evaluation and management (E/M) visits.
[Webinar] 340B… Or Not 340B: Oversight, Compliance and Enforcement - July 15th, 9:00 am - 10:00 am PT | JD Supra
July 15th, 2021 9:00 AM - 10:00 AM PT The 340B Program has gained national attention over the last decade, in part due to the opportunities it provides to generate revenue for participating entities without risk of significant enforcement penalties for non-compliance.
CMS Establishes Online Portal for Case-by-Case Section 1135 Provider Waiver Requests | JD Supra
On January 11, 2021, the Centers for Medicare & Medicaid Services (CMS) released a new web portal to more easily permit healthcare providers and other stakeholders to submit requests for specific waivers of certain healthcare regulatory requirements under Section 1135 of the Social Security Act (Section 1135 waivers). Providers now have the ability to submit requests for waivers to CMS and confirm the presence of existing waivers through a centralized web portal.
Congress Establishes New Medicare Provider Category and Reimbursement for Rural Emergency Hospitals | JD Supra
Year-end COVID-19 relief legislation approved by Congress established Rural Emergency Hospitals (REHs) as a new Medicare provider type effective January 1, 2023. REHs, defined as providers that furnish certain outpatient hospital services in rural areas, including emergency department services, will be reimbursed at a rate higher than the otherwise-applicable payment under the Medicare Outpatient Prospective Payment System (OPPS).
Planning Beyond the Pandemic: Considerations for Hospital and Healthcare Facility Evacuations | JD Supra
In light of recent civil unrest within the United States, which has been accompanied by incidents of property damage and large crowd actions, hospitals and healthcare facilities should consider reviewing and ensuring that their emergency preparedness plans, policies and procedures take into account potential complexities posed by facility evacuation plans during the novel coronavirus (COVID-19) pandemic.
CMS Continues to Refine Survey and Infection Control Guidance for Long-Term Care Facilities During the COVID-19 Pandemic | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CMS Provides Flexibility for Independent Freestanding Emergency Departments to Enroll in Medicare as Hospitals During the COVID-19 Pandemic | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CMS Provides Guidance to Ambulatory Surgical Centers Temporarily Enrolling in Medicare as Hospitals During the COVID-19 Pandemic | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Hospital system pays $84.5 million to settle AKS and Stark Law violations | JD Supra
JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations. This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services").
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