The Medicare Fraud Strike Force initiated its largest ever healthcare enforcement action, charging 412 defendants in July 2017 with approximately $1.3 billion in fraudulent claims. The Strike Force consists of teams that include the Office of Inspector General, the Department of Justice, Offices of the United States Attorneys, the Federal Bureau of Investigation, and local … Continue Reading
While the Senate Budget Committee works to draft legislation to reconcile the American Health Care Act, the repeal and replace bill passed by the House, there is no expectation of a repeal of the charitable care obligations imposed on tax exempt hospitals under Section 501(r) of the Internal Revenue Code as part of the Affordable … Continue Reading
The Centers for Medicare and Medicaid Services (CMS) announced its 2018 Medicare Advantage (MA) capitation rates, with an expected increase of .45 percent, slightly higher than proposed in the advance notice. CMS estimates that MA health plans will realize an increase in revenue of 2.95 percent, reflecting increases in coding acuity and risk adjustment payments. … Continue Reading
Hospitals now have additional time before they must meet federal requirements to provide written notice to Medicare patients who are receiving observation services. Congress passed the Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act) in 2015, in response to patient confusion and complaints related to hospital observation stays. The rules were … Continue Reading
The Department of Health and Human Services Office for Civil Rights (OCR) announced on August 4, 2016, a settlement agreement with Advocate Health Care Network, an integrated healthcare system with ten hospitals and a non-profit medical group of more than 1,500 physicians in Illinois (the System or Advocate). The System agreed to adopt a corrective … Continue Reading
Four years after publication of its proposed rule related to reporting and returning overpayments within 60 days, CMS has issued a final rule that responds to comments and provides greater clarity. The published rule is under the Affordable Care Act requirement that providers report Medicare and Medicaid overpayments and return the overpayment within 60 days … Continue Reading
The Centers for Medicare and Medicaid Services (CMS) has revised the two-midnight rule to create an exception that will allow payment under Medicare Part A for certain medically necessary hospital stays that do not extend across two midnights. The new rule is effective for admissions after January 1, 2016, and permits payment on a case-by-case … Continue Reading
The Office of Inspector General (OIG) recently issued another advisory opinion on free patient transportation (OIG Adv. Op. No. 15-13, dated October 21, 2015). In the opinion, the OIG addresses whether providing patients a free shuttle service between medical facilities operated by an integrated health system (the System) would be prohibited remuneration to beneficiaries under … Continue Reading
Illinois joins a growing number of states to pass laws requiring that hospitals provide notice to patients who are placed under observation status. 210 ILCS 86/6.09b As with the recent federal NOTICE Act, the laws respond to patients not understanding the difference between observation in a hospital bed and inpatient admission. The Illinois law requires … Continue Reading
The NOTICE Act (Notice of Observation Treatment and Implication for Care Eligibility) has been signed into law as of August 6, 2015. The Act requires hospitals to provide oral and written notice to patients within 36 hours of being placed in observation care (or, upon discharge, if sooner). The notice must explain to patients, in … Continue Reading
On June 26, 2015, the Internal Revenue Service (IRS) issued guidance to clarify how charitable hospitals may comply with regulations issued by the Department of Treasury under the Patient Protection and Affordable Care Act (ACA). The regulations implementing Section 501(r) of the Internal Revenue Code require hospitals to include a list of covered providers in … Continue Reading
The Internal Revenue Service (IRS) has issued the final section 501(r) regulations, implementing the amendments to the Internal Revenue Code under the Affordable Care Act and providing regulatory guidance for tax-exempt hospitals. This post describes the guidance for financial assistance policies, limitation on charges, and billing and collection practices and highlights the changes made between … Continue Reading
