Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”) released payment policies for the new Rural Emergency Hospital (“REH”) provider type in the calendar year (“CY”) 2023 Hospital Outpatient Prospective Payment System (“OPPS”) and ASC Payment System Proposed Rule (“OPPS Proposed Rule”) published in the federal register on July 26, 2022. The proposed payment policies... READ MORE

On March 13, 2020, Secretary Azar of the Department of Health and Human Services (the “HHS”) issued a letter titled “Waiver or Modification of Requirements Under Section 1135 of the Social Security Act” (the “Azar Letter”) that grants the Centers for Medicare & Medicaid Services (the “CMS”) the authority to issue waivers specific to... READ MORE

On March 10, 2020, the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum entitled “Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (“COVID-19”) in Home Health Agencies (“HHAs”)” (“QSO Memo”) that announced recommendations for HHAs regarding taking appropriate action to address potential and confirmed COVID-19... READ MORE

On March 17, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum titled “Information for PACE Organizations Regarding Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19)” (“CMS Memo”) that announced COVID‑19 guidance for Programs of All-Inclusive Care for the Elderly (“PACE”) program organizations (“PACE Organization”). The PACE program is a... READ MORE

Hospitals Release Voluntary 340B Principles as Alternative to Legislation The battle over 340B continued this week as hospital groups announced a new voluntary 340B reporting program as an alternative to congressional legislation that would further regulate the program. Under the American Hospital Association-led initiative, hospitals would commit to publicly disclosing their 340B savings annually.... READ MORE

On January 13, 2017, CMS published the revised Conditions of Participation (“CoPs”) for home health agencies, 42 CFR 484, Subparts A, B, and Subpart C. The CoPs became effective on January 13, 2018. On August 31, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum to State Survey Agency Directors (QSO-18-25-HHA) that... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) released a draft of the Interpretive Guidelines (“Draft Interpretive Guidelines”) to the final Conditions of Participation (“CoPs”) for home health agencies that CMS issued in January 2017. The CoPs are scheduled to be implemented January 13, 2018. CMS has asked for feedback on the Draft Interpretive Guidelines. The Draft... READ MORE

Review of the New Home Health Conditions of Participation – Emergency Preparedness, Organization and Administration of Services, Personnel Qualifications and Clinical Records. This is the sixth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they... READ MORE

Review of the New Home Health Conditions of Participation – Patient Rights (part 2). This is the fifth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they proposed to make to the home health... READ MORE

Review of the New Home Health Conditions of Participation – Patient Rights. This is the fourth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they proposed to make to the home health CoPs in... READ MORE