Ober | Kaler Health Law Alert: 2016 Issue 13


CMS Re-proposes Ban on Per-Click Fees for Space and Equipment Leases Under Stark

Prompted by the D.C. Circuit’s opinion in a case challenging CMS’s rulemaking authority, CMS has re-proposed its ban on per-click fees for space and equipment leases. Kristin Bohl and Julie Kass discuss CMS’s revised proposed rule, the background of the rulemaking, and the case that called it into question. Click to continue…

OIG Approves Hospice Payments to Nursing Facility for Dual Eligible Patients Under Medicaid Demonstration Project

The OIG has approved supplemental payments from a hospice to a nursing facility in which a dual eligible hospice patient resides. Bill Mathias and Hannah Clark explain the details of the arrangement and the circumstances that led the OIG to determine not to impose administrative sanctions. Click to continue…


Proposed Cardiac, Hip, and Femur Episode Payment Models Are Next Generation from BPCI and CJR

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on July 25, 2016, entitled, Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR) [PDF], which introduces three new episode payment models (EPMs) and a Cardiac Rehabilitation (CR) incentive payment model under the authority of the Center for Medicare & Medicaid Innovation (CMMI or Innovation Center). In this proposed rule, CMS is building on the bundled payment methodologies it has already implemented under the models for Bundled Payments for Care Improvement (BPCI) and Comprehensive Care for Joint Replacement (CJR), including proposing modifications to the CJR model for conformity with the newly anticipated EPMs.

Ober|Kaler’s Alternative Payment Model Team has published a client alert that begins with an introduction of the new EPMs and follows with a compendium of in-depth discussions on the essential components and structure of these newly proposed payment models. Click to continue…

Health Law Alert® is not to be construed as legal or financial advice, and the review of this information does not create an attorney-client relationship.

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