Articles and Blogs

On September 8, CMS’s Acting Administrator Andy Slavitt announced new options in how MIPS eligible clinicians may participate in MIPS for 2017. In doing so, Mr. Slavitt also stated that CMS will publish the final rule for MIPS, APM incentive payments, etc. no later than November 1, 2016. Mr. Slavitt’s announcement provided only a... READ MORE

The recently passed Wisconsin Act 265 (the “Act”) establishes a new statutory requirement that all “pain clinics” obtain and maintain a special certification to be issued by the Wisconsin Department of Health Services (“DHS”), Division of Quality Assurance (“DQA”). Any organizations engaged in providing pain clinic services should carefully assess whether this requirement applies... READ MORE

On August 22, 2016, the Department of Health and Human Services Office of the Inspector General (“OIG”) released additional guidance (“IRO Guidance”) on relevant principles that should be used to assess the independence of Independent Review Organizations (“IROs”) performing reviews required as a condition of Corporate Integrity Agreements (“CIAs”). This most recent update reflects... READ MORE

Update: The IRS has modified the effective date of Rev. Proc. 2016-44 to extend the transition period by 6 months. The revision allows an issuer to apply the safe harbors in Rev. Proc. 97-13, as modified and amplified, to a management contract entered into before August 18, 2017 and that is not materially modified... READ MORE

Enrollment will soon be closing for the Centers for Medicare and Medicaid Services’ (“CMS”) new Comprehensive Primary Care Plus (“CPC+”) payment model. Building on the success of the Comprehensive Primary Care model, CPC+ aims to strengthen primary care by creating new incentives for providers to invest in resources to improve the quality and efficiency... READ MORE

Late last year, Rep. Edward Canfield (R-Sebewaing) and Sen. Peter MacGregor (R-Rockford) proposed legislation that would amend: (1) the Public Health Code to prohibit the Department of Licensing and Regulatory Affairs or a professional board from requiring a physician to maintain a national or regional certification and prohibits hospitals from denying admitting privileges on... READ MORE

On August 5, 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued an Inpatient Prospective Payment System (“IPPS”) Final Rule (“Final Rule”) adopting the updated labor market area delineations based on the 2010 census. The updated labor market area delineations became effective October 1, 2014. The Final Rule effectively caused, among other changes,... READ MORE

The Department of Health and Human Services Office of Inspector General (“OIG”) recently issued a favorable Advisory Opinion, No. 16-07, of an arrangement that offers Medicare Part D beneficiaries discounts on prescriptions for an erectile dysfunction drug that is statutorily excluded from coverage under Part D (the “Arrangement”). While OIG concluded that the Arrangement... READ MORE

On August 2, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a Proposed Rule establishing three new mandatory retrospective bundled payment models and creating an incentive payment program for cardiac rehabilitation services. In this Proposed Rule, CMS also outlined several proposed changes to the recently implemented Comprehensive Care for Joint Replacement (“CJR”)... READ MORE

Background On August 2, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule (the “Proposed Rule“) to create three new episode payment models (“EPMs”) covering services provided to Medicare beneficiaries admitted to certain Inpatient Prospective Payment System (“IPPS”) hospitals for heart attacks, coronary bypass surgery or surgical treatment of hip... READ MORE