Articles and Blogs

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

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

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

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

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

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

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

Yesterday, CMS posted the following update to its Inpatient Hospital Reviews page:  READ MORE

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

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