Long-Term Care Hospitals and Satellite Development Projects to be Impacted by Passage of the “Doc Fix” Bill

Posted by Jason Greis on March 27, 2014 under Articles | Be the First to Comment

On March 27, 2014, the House of Representatives approved a bill (H.R. 4302) by voice vote to extend Medicare physician pay rates through March 31, 2015 after House Republican leaders scrambled to round up support for the measure.  Following the House action, the one-year patch for Medicare’s physician pay rates, which are otherwise scheduled to be cut by 24% beginning April 1, was sent to the Senate.  Passage of a version of the “Doc Fix” Bill is anticipated early next week. Read More...

2014 OIG Work Plan Released: Our Observations on Enforcement

Posted by Jason Greis on February 19, 2014 under Articles | Be the First to Comment

The Office of the Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) recently released its Work Plan for Fiscal Year 2014 (the “Work Plan”).  Usually issued in October, budget pressures delayed this year’s release.  The Work Plan provides an annual view into the OIG’s planned areas of focus for investigation and enforcement activities in the coming year.  Below are a few interesting observations from this year’s Work Plan. Read More...

CMS Announces Winter 2014 Open Period for Participation in Bundled Payments for Care Improvement Initiative

Posted by Jason Greis on February 18, 2014 under Articles | Be the First to Comment

On February 14, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a notice in the Federal Register announcing an open period for additional organizations to be considered for participation in models 2, 3 and 4 of its Bundled Payments for Care Improvement (BPCI) initiative.  The BPCI initiative was developed by the CMS Innovation Center, which was created by the Patient Protection and Affordable Care Act to test innovative payment and service delivery models that have the potential to reduce Medicare, Medicaid or Children’s Health Insurance Program (CHIP) expenditures while preserving or enhancing the quality of care for beneficiaries.  Under the BPCI initiative, organizations enter into payment arrangements intended to promote higher quality, lower cost coordinated care across an episode of care.  The BPCI initiative is comprised of four broadly defined models of care that bundle payments for multiple services, which beneficiaries typically receive during an episode of care. Read More...

MedPAC Votes Again to Recommend an 8-Day ICU Length of Stay to Qualify for LTCH-PPS Payments

Posted by Jason Greis on February 11, 2014 under Articles | Be the First to Comment

In January 2014, the Medicare Payment Advisory Commission (MedPAC), a commission that provides non-binding but influential recommendations to Congress on Medicare issues and related payment policies, voted to recommend for Congress to pass legislation requiring an 8-day length of patient stay in an intensive care unit (ICU) of a general acute care hospital before admission to a Long Term Care Hospital (LTCH) would trigger higher reimbursement to LTCHs under the Long-Term Care Hospital Prospective Payment System (LTCH-PPS). Read More...

Judge Orders Health System Divestiture of Physician Group Practice Due to Antitrust Concerns

Posted by Jason Greis on February 3, 2014 under Articles | Be the First to Comment

For the first time, a federal district judge has required the unwinding of a hospital’s acquisition of a physician group practice due to antitrust concerns. As a result of the ruling, released Jan. 24, 2014, the largest health system in Idaho, St. Luke’s Health System, must divest the state’s largest independent medical group, Saltzer Medical Group (SMG). The ruling sends a clear message that hospitals’ acquisitions of physician group practices are not immune from antitrust scrutiny and may require careful analysis under the antitrust laws. Read More...

Impact of the Bipartisan Budget Act of 2013 on LTACHs: Six Key Changes

Posted by Jason Greis on December 18, 2013 under Articles | Be the First to Comment

With Congress having adopted its first budget resolution in several years, many questions have arisen as to what the legislation means for the federal government, businesses and individual taxpayers. In order to understand the budget deal, it is important to consider the context within which the agreement was reached, as well as the specific provisions it contains. Doing so allows for a more effective examination of the goals and potential impact of this significant, albeit incremental, measure. Read More...