Katy Appleby

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

Bundled Payments Out in the Cold? Another Delay for Mandatory Bundled Payment Models

By Kristen McDermott Woodrum and Katy Appleby on April 12, 2017 Posted in Uncategorized

This most recent delay raises questions concerning how the Trump administration intends to implement value-based payment in the Medicare program. The Centers for Medicare and Medicaid Services (CMS) has delayed again the implementation date of its final rule mandating hospital participation in two new cardiac episode-based payment models (EPMs) and an expansion of the Comprehensive … Continue Reading

Destination Medicine: Not Just for the Rich and Famous

By Katy Appleby and Banee Pachuca on March 28, 2017 Posted in Uncategorized

OIG okays providing modest hotel and meal accommodations for rural and financially needy patients. The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued an advisory opinion interpreting the finalized rules related to the beneficiary inducement civil monetary penalties (CMP) law. In a previous blog post, we discussed the OIG … Continue Reading

CMS Finalizes Mandatory Cardiac and Joint Bundles … But Their Future is Uncertain

By Kristen McDermott Woodrum and Katy Appleby on January 17, 2017 Posted in Uncategorized

When Tom Price assumes the top post at the U.S. Department of Health and Human Services (HHS) later this month (subject to Senate confirmation), the ink will barely be dry on a final rule issued by the Centers for Medicare & Medicaid Services (CMS) mandating hospital participation in two new cardiac episode-based payment models (EPMs) and an … Continue Reading

Making Sense of MACRA

By Kristen McDermott Woodrum and Katy Appleby on November 9, 2016 Posted in Uncategorized

Bracing for the Medicare Part B Overhaul: Pick a Path, Pick a Pace The countdown has begun for the momentous Part B payment reforms created by the Medicare Access and Chip Reauthorization Act of 2015 (MACRA). On October 14, 2016, CMS released a final rule explaining, in nearly 2,400 pages, how its new Quality Payment Program, established under MACRA, … Continue Reading

Come On In and Stay Awhile: IRS Expands Safe Harbors for Bond-Financed Property

By Katy Appleby, Emily Crosby and Christopher Swift on October 17, 2016 Posted in Uncategorized

The Internal Revenue Service recently issued guidance in Rev. Proc. 2016-44 that meaningfully expands the safe harbors pertaining to management contracts affecting bond-financed property such as professional services agreements (e.g., radiology), medical director agreements, on-call agreements, food service agreements and management services agreements. While the new framework offers clarity and increased flexibility for Section 501(c)(3) organizations in … Continue Reading