Articles and Blogs

On November 20, 2020, the Office of the Inspector General (“OIG”) and Centers for Medicare & Medicaid Services (“CMS”) issued final rules (the “Final Rules”) revising and expanding exceptions and safe harbors under the federal Stark Law (“Stark”) and Anti-Kickback Statute (“AKS”) as part of the Department of Health and Human Services’ “Regulatory Sprint... READ MORE

The government continues to implement payment reforms and to lay the groundwork for the continuing shift in health care from a volume-based “fee-for-service” model to a value-based system that incentivizes outcomes and reductions in cost. Below we’ve outlined some immediate steps that health care organizations can take now to incorporate quality, value and cost... READ MORE

S&P Global Ratings, Fitch Ratings and Moody’s Investors Service recently released their Nonprofit Healthcare 2019 Outlooks, which are largely consistent with 2018, despite changes in the health care industry over the past year. Fitch and Moody’s issued negative outlooks for the nonprofit health care sector, while S&P’s sector outlook was stable. Despite their differing... READ MORE

HHS Previews 2019 Regulatory Agenda At a symposium on Tuesday, Deputy HHS Secretary Eric Hargan and CMS Administrator Seema Verma outlined the administration’s health care strategy for 2019, which includes advancing the use of technology, adjusting payments in rural areas and testing new ways to reward high-quality care and reforms to the Stark and... READ MORE

On June 20, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Request for Information (“RFI”) seeking feedback from health care industry stakeholders on the burdens of compliance with the Stark Law as it exists today. Earlier in the day, Kelly Cleary from the HHS Office of the General Counsel and HHS... READ MORE

Azar Pushes Value-Based Care Approach  During the annual policy conference for the Federation of American Hospitals, Health and Human Services (“HHS”) Secretary Alex Azar laid out an agenda for a more cost-effective and transparent health care system. Azar said HHS is focused on four key priorities: giving consumers greater control over health information through... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) announced its long-awaited “BPCI Advanced” model on January 9. The model – which is voluntary – will initially include 29 inpatient clinical episodes and 3 outpatient clinical episodes (a list of the 32 clinical episodes can be found here). BPCI Advanced Participants must elect to be... READ MORE