In our blog post of July 10, 2018, we discussed the key elements of the Final Rule issued on June 21, 2018 with respect to Association Health Plans (AHPs). As we noted, the expansion of ERISA’s definition of an employer and the other elements of the Final Rule designed to expand insurance opportunities for small…… Continue reading this entry
The telemedicine industry was pleased to learn CMS recently proposed adding new services to its list of Medicare-covered telehealth services. But what may be more interesting are the services CMS declined to add, and why. This article summarizes the newly-proposed additions as well as the services CMS rejected, explores some reasons for CMS’ decisions, and…… Continue reading this entry
On Tuesday, July 17, 2018, the United States Court of Appeals for the District of Columbia ended a challenge brought by hospitals and hospital associations to the nearly 28 percent reimbursement cuts for 340B hospitals under the Medicare program. The payment cuts were finalized in the calendar year (CY) 2018 Medicare Outpatient Prospective Payment System…… Continue reading this entry
The Centers for Medicaid & Medicare Services (CMS) proposes to revise regulations issued pursuant to the Federal physician self-referrals Statute (Stark Law) to harmonize the regulations with the newly enacted Bipartisan Budget Act of 2018 (Pub. L. 115-123, enacted on February 9, 2018). Stark Law generally prohibits Medicare payment for claims resulting from physician referrals for…… Continue reading this entry
Earlier this year, in a first-of-its-kind move, CMS made remote patient monitoring (RPM) a separately-reimbursable service under Medicare. Now, CMS has proposed three new codes for RPM services, retitled “Chronic Care Remote Physiologic Monitoring,” which do a far better job reflecting how providers can more effectively and efficiently use RPM technology to monitor and manage…… Continue reading this entry
There are many health care financial arrangements where one entity has a financial obligation to another, with whom it either does business directly, or to which it makes referrals, and that obligation is either past due or for one reason or another cannot be paid. This may come up, for example, in the context of…… Continue reading this entry
The Massachusetts House of Representatives has passed sweeping telehealth legislation, accompanying a companion bill passed by the Senate in November 2017. While Massachusetts is often considered a leader in health care innovation, the Commonwealth has not enacted significant legislation in this area for several years, and is among the minority of states without a meaningful telehealth insurance coverage…… Continue reading this entry
Providers and suppliers who have been assessed overpayments for Medicare services are entitled, by statute, to a stay of recoupment while the provider or supplier’s appeal is pending – but only at the first two levels of administrative appeal. If both appeals are unfavorable to the provider or supplier, the next step is an appeal…… Continue reading this entry
The Centers for Medicare and Medicaid Services just issued a proposed rule introducing monumental changes to the physician fee schedule, paving the way for asynchronous telemedicine and new technologies through a new set of virtual care codes. CMS explained the impetus for the bold changes, declaring: “We now recognize that advances in communication technology have…… Continue reading this entry
CMS recently announced that it wants to launch a new demonstration program, the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration. If approved and adopted as a demonstration project, the MAQI Demonstration would waive Merit-Based Incentive Payment System (MIPS) requirements for clinicians who participate sufficiently in qualifying risk programs of Medicare Advantage plans by making…… Continue reading this entry