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On November 2, 2018, CMS released an on-line display copy of its Outpatient Prospective Payment System (OPPS) Final Rule implementing payment changes effective January 1, 2019. The official Federal Issuance is expected on November 21, 2018.  One anticipated set of changes in the Final Rule is related to off-campus outpatient hospital departments (OCODPs).…
On November 6, 2018, when Massachusetts voters go to the polls to select a new Governor and other key elected officers, they will also consider Ballot Question 1, which will mandate rigid registered nurse staffing ratios for hospitals across the Commonwealth effective as of January 1, 2019. This proposal would make Massachusetts the second state in the United States to have specific staffing ratios mandated in all units. This initiative follows only California, which…
Hospitals with off-campus provider-based departments (PBDs) may want to rethink their end of summer vacation plans in order to focus on a recent slate of proposed regulations from the Center for Medicare and Medicaid Services (CMS) that seek to rein in Medicare reimbursement for outpatient hospital services – including at excepted/grandfathered off-campus locations.…
On June 19 and 20, 2018, more than 60 innovators and thought leaders came together for the 13th annual, invitation-only CEO/Innovators Roundtable (Roundtable), hosted by Foley & Lardner LLP and BDC Advisors, LLC. The overall theme of the Roundtable was “disruption and innovation” in health care, and the discussion was divided into panels on five key topics: Re-engineering Primary Care Digital Therapies and Distributed Care Big Data and Machine Learning Consumer Engagement Health Company…
On June 19 and 20, 2018, more than 60 innovators and thought leaders came together for the 13th annual, invitation-only CEO/Innovators Roundtable (Roundtable), hosted by Foley & Lardner LLP and BDC Advisors, LLC. The overall theme of the Roundtable was “disruption and innovation” in health care, and the discussion was divided into panels on five key topics: Re-engineering Primary Care Digital Therapies and Distributed Care Big Data and Machine Learning Consumer Engagement Health Company…
In some states, including the Commonwealth of Massachusetts, “site neutrality” for outpatient hospital reimbursement is factoring into state-specific health reform and cost containment initiatives. This potentially goes well-beyond Medicare’s limitation of reimbursement at new off-campus outpatient hospital departments under Section 603 of the Bi-partisan Budget Act of 2015. Since Massachusetts’ state health reform law was the model on which the Affordable Care Act was based, many other jurisdictions look to Massachusetts to…
On Monday, two House committees with oversight over health care and taxation, Energy and Commerce and Ways and Means, released draft reconciliation bills designed to repeal and alter significant portions of the Patient Protection and Affordable Care Act (PPACA).  These long-awaited draft bills, collectively entitled the American Health Care Act (AHCA), would make significant modifications to the health insurance markets and to the operation of state Medicaid programs, and would also repeal or delay…
The 21st Century Cures Act (the “Cures Act”) (Pub. L. No. 114-255), which was signed into law by President Obama on December 13, 2016, includes a number of important health care provisions, and several address the long-anticipated relief for Medicare “site-neutrality” policies relating to off-campus outpatient hospital departments (“OCODPs”), certain cancer hospitals, and long-term care hospitals (“LTCHs”). The Cures Act is one of the few, broadly supported, bi-partisan health care related bills to pass Congress…
Center for Medicare and Medicaid Services (CMS) issued the long-awaited implementation of the “site-neutrality” provisions of the H.R. 1314 Bipartisan Budget Act of 2015 (BiBA Section 603) on November 1, 2016. The Final Rule will cause new (non-grandfathered) hospital off-campus outpatient departments to no longer be reimbursed under the Medicare Outpatient Prospective Payment System (OPPS). Rather, those locations will receive something less than 50% of the old OPPS rate (at least initially) to approximate Medicare