Kristen McDermott Woodrum

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Stark and AKS Rules Cross the Finish Line of HHS Regulatory Sprint

With a bold finish, the Department of Health and Human Services (HHS) crossed the finish line of its race to modernize and clarify the regulations interpreting the federal physician self-referral law (Stark) and anti-kickback statute (AKS) through final rules released Nov. 20, 2020. With one exception, the Stark and AKS rules, based on October 2019 … Continue Reading

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

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

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

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

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

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

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

21st Century Cures: Not Just a Biomed Bill

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

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

Making Sense of MACRA

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

Year of the Bundle: CMS Proposes New Mandatory Cardiac Bundles and Expansion of CCJR

CMS is building momentum with its bundled payment programs and upping the stakes for hospitals. The Centers for Medicare & Medicaid Services (CMS) recently published a proposed rule that furthers the U.S. Department of Health and Human Services’ goal to promote cooperative, value-based care and tie at least 50 percent of Medicare payments to quality … Continue Reading

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

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

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

CMS Finalizes Revisions to Stark to Ease Burden on Providers, Refines “Incident to” Requirements

In its calendar year 2016 Physician Fee Schedule Final Rule published in the Federal Register on November 16, 2015 (Final Rule), the Centers for Medicare and Medicaid Services (CMS) finalized amendments to the federal physician self-referral (Stark) regulations proposed in the Physician Fee Schedule proposed rule released in July. Among the significant provisions contained in the Final Rule are … Continue Reading

The Deeper Dive: Medicare’s Fundamental Shift Toward P4P

What priorities should providers focus on in navigating the changing payment environment? While Medicare’s path toward pay for performance (P4P) has evolved over time, 2015 is proving to be a landmark year. July marked the 50th anniversary of the Medicare program. And in self-described “historic announcements” earlier this year, the U.S. Department of Health and … Continue Reading

Proposed Rule Aims to Refine Stark Regulations and Clarify “Incident To”

On July 15, 2015, the Centers for Medicare and Medicaid Services (CMS) published the calendar year (CY) 2016 Physician Fee Schedule Proposed Rule. In addition to updating several traditional Part B payment policies, the proposed rule contains significant changes to the physician self-referral regulations (Stark regulations) and the Medicare “incident to” coverage rule. The comment … Continue Reading
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