Provider-based facilities may share space with a freestanding entity. Any provider that has an arrangement under which there is a freestanding clinic in a building that also contains provider-based or hospital space needs to understand both the relevant Centers for Medicare & Medicaid Services (CMS) policy and the law related…
Proposed changes will impact hospitals, critical access hospitals, inpatient rehabilitation facilities, and home health agencies. The Centers for Medicare & Medicaid Services (CMS) back in 2015 proposed changes to the Conditions of Participation (CoP) found in 42 CFR part 482. The rationale for the changes is provided in elegant detail…
Lack of auditor response leads to an ALJ hearing. “A stitch in time saves nine” is a pretty famous heuristic expression, but most people I know do not have any idea what it means. Simply stated, it means that taking the time to do something correctly now will save time…
OIG report cites widespread MAO problems related to denials of care and payment. Medicare and Medicaid are moving steadily into a capitated model system – or should I say, “have moved.” A central concern about the capitated payment model used in Medicare Advantage is the financial incentive for Medicare Advantage…
Document was reportedly not to be shared with providers An internal Centers for Medicare & Medicaid Services (CMS) memo on inpatient admission orders has come into possession of RACmonitor.  The memo, dated Oct. 3, was written to “clarify” the 2019 fiscal year Inpatient Prospective Payment System (IPPS) final rule for…
A brewing problem, or simply an area for clarification for IRFs?   During what was expected to be a plain vanilla review of the Inpatient Rehabilitation Facility Prospective Payment Systems (IRF-PPS) Coverage Requirements and Updates from the FY 2019 Final Rule, the Centers for Medicare & Medicaid Services (CMS) made…
OIG discusses plans in 2018 Work Plan update The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) announced on Thursday that the agency, along with the Centers for Medicare & Medicaid Services (CMS), has noted “problems” with upcoding in hospital billing to increase payment. As…
The Centers for Medicare & Medicaid Services (CMS) has informed state Medicaid directors that it intends to expand mental health treatment services via a new Medicaid demonstration project, the agency announced in a press release issued Tuesday. In a letter to the state Medicaid directors, CMS reportedly outlined existing and…
Highlights of the 2019 Medicare Physician Fee Schedule, released on Nov. 1, are provided by the author. There will be no change in E&M payment levels for 2019, as was proposed in the Centers for Medicare & Medicaid Services (CMS) proposed, rule, news that comes as a relief to many…
“Outpatient” does not equate “same-day.” By this time last year, the Centers for Medicare & Medicaid Services (CMS) had notified providers that they were removing total knee arthroplasty (TKA) from the Medicare inpatient-only list. While the cries of disbelief and howls of frustration eventually died down after a few months,…