Ernessa McKie

Structuring Clinical Practices to Prevent Pitfalls – Deeply Rooted Corporate Practice Doctrine Remains Strong

By Vimala Devassy and Ernessa McKie on October 18, 2017 Posted in Uncategorized

With growing patient demands, advanced technology and payer restraints, healthcare providers are increasingly exploring management agreements with experienced companies to handle the daily operations of their clinical practice. However, healthcare professionals need to be aware of the potential pitfalls in doing so, especially given the deeply rooted corporate practice of medicine doctrine in many states, … Continue Reading

Back to School Rules Recap: Hospital and Physician Cheat Sheet on What CMS Did This Summer

By Kristen McDermott Woodrum, Ernessa McKie and Jeff Murray on August 25, 2017 Posted in Uncategorized

Summer was no vacation for the Centers for Medicare & Medicaid Services (CMS). The agency released a series of significant rules that signal the nature and pace of CMS Medicare payment and policy changes for hospitals and physicians under the Trump administration. For anyone who did take a vacation, this article provides a rulemaking cheat … Continue Reading

CMS Proposes CY 2018 Quality Payment Program Policy Changes that Signal Intent to Reduce the Pace and Burdens of MACRA

By Kristen McDermott Woodrum and Ernessa McKie on July 18, 2017 Posted in Uncategorized

On June 30, the Centers for Medicare & Medicaid Services (CMS) issued a much anticipated rule outlining proposed payment and policy changes to the new Medicare Part B Quality Payment Program (QPP) that was created by the Medicare Access and Chip Reauthorization Act of 2015 (MACRA). The proposed rule seeks to offer additional flexibility and … Continue Reading

Ch-Ch-Ch-Ch-Changes: Reporting Requirements for Updating Your CMS Provider Enrollment

By Charlotte Combre and Ernessa McKie on June 22, 2017 Posted in Uncategorized

With the possibility of significant penalties for improperly reported transactions, it is important to understand how certain changes necessitate specific reporting. Is your organization considering a stock transfer, a merger, a change in control, building a new practice location or updating its board of directors? If these kinds of changes are afoot, it is critical … Continue Reading

IPPS Proposed Rule Increases Hospital Payment; Solicits Ideas for Achieving Transparency, Relieving Administrative Burden

By Amy Fouts, Ernessa McKie and Katy Appleby on May 10, 2017 Posted in Uncategorized

The Centers for Medicare & Medicaid Services (CMS) recently issued its proposed rule updating fiscal year (FY) 2018 payment policies and rates under the Medicare inpatient prospective payment system (IPPS). As highlighted below, the proposed rule aims to reduce regulatory burdens for providers and to promote transparency and flexibility in the delivery of care. Comments … Continue Reading

More Time to Streamline: NIH Extends Deadline for Implementation of Single IRBs for Funded Studies

By Ernessa McKie on February 2, 2017 Posted in Uncategorized

The research community has a full plate as it sifts through the final rule on the Common Rule issued last week. Many are now fully appreciating the December gift from the National Institutes of Health that granted an extension for developing policies to streamline multi-site studies under a single Institutional Review Board (IRB). On December … Continue Reading

21st Century Cures: Not Just a Biomed Bill

By Kristen McDermott Woodrum and Ernessa McKie on December 19, 2016 Posted in Uncategorized

The 21st Century Cures Act signed into law on December 13, 2016 is gaining significant attention as landmark legislation promoting medical innovation. But the massive Cures Act goes much further and includes some relief (though not a complete cure) for certain hospitals impacted by the site-neutral payment policies of Section 603 of the Bipartisan Budget … Continue Reading

The Wait is Over: CMS Delivers Post-BBA Provider-Based Policies in Final 2017 OPPS

By Kristen McDermott Woodrum, Susan Feigin Harris and Ernessa McKie on November 23, 2016 Posted in Uncategorized

Now that the rule is out, work to implement the BBA changes begins in earnest. CMS commemorated the one-year anniversary of the Bipartisan Budget Act of 2015 (BBA) with the traditional gift of paper, offering long-awaited guidance to hospitals on how the agency will implement the site-neutral payment policies of BBA Section 603 in the … Continue Reading

More Than the Leaves Are Changing: Clinical Trial Research Regulations and Policies Get a Fall Makeover

By Payal Cramer and Ernessa McKie on October 24, 2016 Posted in Uncategorized

These changes represent a new season of responsibilities for those who manage and oversee clinical trials. The Food and Drug Administration (FDA) and National Institutes of Health (NIH) have recently finalized or signaled intent to finalize numerous proposals that promise to change the landscape of clinical trial reporting, clinical researcher responsibility and Institutional Review Board … Continue Reading

Provider-Based Status Post-BBA: CMS Offers Limited Answers, Requests More Feedback

By Susan Feigin Harris, Kristen McDermott Woodrum, Ernessa McKie and Summer D. Swallow on July 25, 2016 Posted in Uncategorized

For those in the hospital industry hoping for additional clarity regarding the operation and billing of provider-based departments (PBDs), the CY 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule provides some much-needed insight but raises additional concerns. In the Proposed Rule, the Centers for Medicare & Medicaid Services (CMS) sets forth how the agency intends to … Continue Reading

The Future of Provider-Based Status Post-BBA 2015

By Kristen McDermott Woodrum, Susan Feigin Harris and Ernessa McKie on June 20, 2016 Posted in Uncategorized

Examining Possible Congressional Relief and CMS Guidance This month, hospitals impacted by Section 603 of the Bipartisan Budget Act of 2015 (BBA) may finally get a glimpse of what the future holds for the off-campus departments they operated or were developing when the BBA was enacted on November 2, 2015. Section 603 introduced site neutrality … Continue Reading

FY 2017 IPPS Proposed Rule Results in Modest Increase for Hospitals

By Amy Fouts, Ernessa McKie and Kyle Gregory on May 13, 2016 Posted in Uncategorized

CMS recently issued a proposed rule updating fiscal year (FY) 2017 Medicare payment policies and rates under the Medicare inpatient prospective payment system (IPPS) and the long-term care hospital (LTCH) prospective payment system. Highlights of the proposed rule applicable to IPPS hospitals are the focus of this summary. With the proposed rule, CMS continues to emphasize its … Continue Reading