Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”) has posted a listing of providers who have already been sent a request to revalidate their Medicare enrollment information.  The listing contains the name and National Provider Identifier (“NPI”) of each provider, as well as the date the letter was sent.  Providers on the list, but... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) has made changes to the Medicare Overpayment Notification Process.  If an outstanding balance has not been resolved, providers previously received three notification letters regarding the overpayments:  (1) an initial demand letter, (2) a follow-up letter, and then (3) an intent to refer letter.  CMS would send the second... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) has reevaluated the revalidation requirements in the Affordable Care Act (“ACA”), and believe the ACA allows for the extension of the revalidation period for an additional two years.  This will extend the deadline for revalidation through March of 2015.  Providers are reminded that if they have... READ MORE

On October 31, 2011, the final rule (Rule) to update the Home Health Prospective Payment System (HH PPS) for Calendar Year 2012 was published in the Federal Register.  As a result of the Centers for Medicare & Medicaid Services (CMS) implementing the Rule, home health agencies (HHAs) will experience a decrease in payments of... READ MORE

Pursuant to Section 6111 of the Affordable Care Act enacted on March 23, 2010, and the final rule published on March 18, 2011 in the Federal Register, a nursing facility must be offered the opportunity to request an Independent Informal Dispute Resolution (IIDR) if the Centers for Medicare & Medicaid Services (CMS) imposes a... READ MORE

CMS has just released the highly anticipated final regulations for accountable care organizations (ACOs) under Section 3022 of the Affordable Care Act (ACA).  The ACA requires accountable-care agreements to be offered under Medicare, starting in 2012.  READ MORE

Just weeks after ongoing development of the CLASS Act stalled, Secretary Sebelius announced today the implementation of the CLASS Act has been completely halted.  Reflecting concerns over the sustainability of the program and the potential for the development of a new entitlement program, the Department of Health and Human Services determined the financing plans related to the Act... READ MORE

Representative John Kline of Minnesota introduced the Workforce Democracy and Fairness Act last week in response to recent NLRB actions affecting employers.  One aspect of this Bill is the reversal of the NLRB’s Specialty Healthcare decision which altered the established standard for determining collective bargaining units in non-acute care health facilities.    READ MORE

As previously discussed, hospice providers are required to have a hospice physician or nurse practitioner perform a face-to-face encounter with each hospice patient whose total length of stay is anticipated to reach the third benefit period.  This encounter must be performed no more than thirty days prior to the third benefit period recertification, and... READ MORE

The NLRB announced last week that it has postponed the implementation date for its new notice-posting rule (previously discussed here and here) by more than two months in order to allow for “enhanced education and outreach to employers”, particularly those who operate small and medium sized businesses.  The posting requirement for most private employers... READ MORE