Articles and Blogs

The Consolidated Appropriations Act, 2021 (the “Act”) signed into law on December 27, 2020, created a new Medicare provider type called a Rural Emergency Hospital (“REH”). Critical access hospitals (“CAHs”) and rural hospitals with 50 beds or fewer could transition to REH status starting January 1, 2023. On June 30, 2022, the Centers for... READ MORE

The health care industry has experienced significant increases in cyber-attacks such as ransomware the past few years. One segment of the industry that may be impacted especially hard by these increased attacks is Critical Access Hospitals (“CAHs”). Due to the increasing number of cyber-attacks, insurance underwriting practices are shifting. Instead of virtually rubberstamping each application... READ MORE

On September 30, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule regarding discharge planning (“Final Rule”) addressing care transitions and patient access to medical information. CMS had initially issued the proposed regulations in November 2015 to update discharge planning requirements for hospitals[1], critical access hospitals (“CAHs”) and post-acute care... READ MORE

On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released its proposed rule for Calendar Year (“CY”) 2020 Hospital Outpatient Prospective Payment System (“Proposed Rule”). Among many other changes, CMS proposed three key payment policy updates impacting hospital outpatient departments, including: (1) lowering the supervision standard for hospital outpatient therapeutic services... READ MORE

On May 3, 2019, CMS released its long-awaited guidance on hospital co-location and shared service arrangements in the form of a draft survey memo (“Memo”), which is available here. The Memo clarifies how a hospital can co-locate with other health care entities without violating the Medicare Conditions of Participation (“CoPs”). CMS has been promising... READ MORE