CMS Proposes Updates to Medicare Hospice Wage Index/Rates for FY 2016

CMS published a proposed rule on May 5, 2015 that would update Medicare hospice payment rates and the wage index for fiscal year (FY) 2016. CMS estimates that the proposed rule would increase overall payments to hospices by about 1.3%, or $200 million, in FY 2016. This increase reflects a 1.8% proposed FY 2016 hospice payment update, which is reduced by the use of updated wage index data and the last year of the phase-out of the wage index budget neutrality adjustment factor (-0.7% decrease), and further increased as a result of a transition to new Office of Management and Budget Core Based Statistical Area (CBSA) delineations for the FY 2016 hospice wage index (0.2% increase).

In addition, CMS proposes to create two different payment rates for routine home care (RHC) that would provide a higher base payment rate for the first 60 days of hospice care and a reduced base payment rate for subsequent days. CMS also would establish a service intensity add-on (SIA) payment for services provided in the last 7 days of a beneficiary's life, if the following criteria are met: (1) the day must be billed as a RHC level of care day; (2) the day must occur during the last 7 days of life (and the beneficiary is discharged dead); (3) direct patient care must be provided by a RN or a social worker; and (4) the service may not be provided in a skilled nursing facility or nursing facility. The proposed SIA payment would equal the continuous home care (CHC) hourly payment rate multiplied by the amount of direct patient care provided by a RN or social worker for up to 4 hours total, per day, as long as the four criteria are met.

The proposed rule also would, among other things: implement Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) changes to the aggregate cap calculation; align the cap accounting year for both the inpatient cap and the hospice aggregate cap with the federal fiscal year starting in FY 2017; make changes to the hospice quality reporting program; and clarify requirements for diagnosis reporting on the hospice claim.  CMS will accept comments on the proposed rule until June 29, 2015.

CMS Clarifies FY 2016 IPPS/LTCH Proposed Rule Comment Deadline

CMS has published a correction notice that clarifies that the comment deadline for the FY 2016 Medicare inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) PPS proposed rule is June 16, 2015 (as the agency announced when the rule was released). The version of the rule published in the Federal Register on April 30 incorrectly stated that the comment deadline is June 29, 2015.

CMS Updates Part D Prescribing Regulations

CMS published an interim final rule with comment period (IFC) on May 6, 2015 that modifies a previously-adopted regulatory requirement regarding qualifications to prescribe Part D drugs. By way of background, under a final rule published May 23, 2014, Part D sponsors must deny a pharmacy claim for a Part D drug if the physician or eligible professional who wrote the prescription is neither enrolled in nor validly opted-out of Medicare. CMS previously announced that it was not enforcing the enrollment requirement until December 2015 to allow additional time for Part D prescribers to enroll in or opt-out of Medicare.

CMS has subsequently learned that certain pharmacists and other provider types who do not meet the statutory definitions of “physician” or “eligible professional” to enroll in Medicare may prescribe drugs under state law, but their prescriptions would be denied under the CMS rule because the prescriber is neither enrolled in nor opted-out of Medicare. In response, the May 6 IFC provides that pharmacy claims and beneficiary requests for reimbursement for Medicare Part D prescriptions, written by prescribers other than physicians and eligible professionals who are permitted by state or other applicable law to prescribe medications, will not be rejected at the point of sale or denied by the plan if all other requirements are met. In addition, to mitigate potential interruptions to beneficiaries’ access to medications, the IFC requires Part D sponsors to cover a provisional supply of drugs (3 months) and provide beneficiaries with individualized written notice before denying a Part D claim or beneficiary request for reimbursement on the basis of a prescriber’s Medicare enrollment status. The IFC applies the enrollment policy effective January 1, 2016. Comments will be accepted until July 6, 2015.

CMS Issues Proposed Rule to Update FY 2016 IPPS, LTCH PPS Rates, Policies

On April 30, 2015, the Centers for Medicare & Medicaid Services (CMS) is publishing its proposed rule to update the Medicare acute hospital inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2016.  CMS will accept comments on the proposed rule until June 16, 2015. The final rule will be published by August 1, 2015, and generally will apply to discharges occurring on or after October 1, 2015.

With regard to the IPPS, CMS projects that the rate and policy changes in the proposed rule would increase IPPS operating payments by approximately 0.3%, or about $120 million in FY 2016. The proposed rule would provide for a 1.1% operating payment rate update for hospitals that submit quality data and are meaningful users of Electronic Health Records (EHR). This update reflects a 2.7% market basket update, adjusted by a -0.6 percentage point multi-factor productivity (MFP) cut and an additional -0.2 percentage point cut (as mandated by the Affordable Care Act, or ACA), with an additional -0.8 percentage point documentation and coding recoupment adjustment required by the American Taxpayer Relief Act of 2012.

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CMS Releases Proposed FY 2016 Medicare Inpatient Psychiatric Facilities PPS Update

CMS issued a proposed rule on April 24, 2015 that would update FY 2016 Medicare payment policies and rates for the Inpatient Psychiatric Facilities (IPF) PPS. The proposed rule also would update quality measures and reporting requirements under the the IPF Quality Reporting Program, under which facilities report on quality measures or are subject to a 2 percentage point reduction in their annual payment update. The proposed rule would expand the measure sets in future fiscal years and change certain data reporting requirements for these measures. CMS proposes a 1.6% update for FY 2015, which would increase aggregate payments by $80 million compared to FY 2015 levels. The proposed update reflects a 2.7% increase under a proposed new IPF-specific market basket, reduced by a 0.6 percentage point productivity adjustment and an additional 0.2 percentage point reduction under the ACA, and further reduced by 0.3% as a result of an update of the outlier fixed-dollar loss threshold amount. CMS also proposes to transition to new Core Based Statistical Area (CBSA) designations in IPF PPS wage index, and phase out the rural adjustment for IPF providers whose status changes from rural to urban as a result of the proposed wage index CBSA changes.  The official version of the rule will be published on May 1, 2015, and CMS will accept comments on the proposed rule until June 23, 2015.

CMS Proposes FY 2016 Update to SNF PPS Rates, Policies

On April 20, 2015, CMS published its proposed rule updating Medicare skilled nursing facility (SNF) PPS rates and policies for FY 2016. CMS projects that the proposed rule would increase overall payments to SNFs by $500 million, or 1.4%, compared to FY 2015 levels. This update would be attributed to a 2.6% market basket increase that would be reduced by a 0.6 percentage point forecast error adjustment and a 0.6 percentage point multifactor productivity adjustment.

The proposed rule also would implement a provision of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) that reduces, by two percentage points, the annual update to SNFs that fail to submit required quality data to CMS under the SNF Quality Reporting Program (QRP), beginning with FY 2018. CMS is proposing to adopt three measures SNFs would be required to report beginning with the FY 2018 SNF QRP that address three quality domains identified in the IMPACT Act: (1) skin integrity and changes in skin integrity; (2) incidence of major falls; and (3) functional status, cognitive function, and changes in function and cognitive function. The proposed measures are intended to address the IMPACT Act requirement of standardized post-acute care data reporting across home health agencies, inpatient rehabilitation facilities, long term care hospitals, and SNFs. CMS intends to propose additional quality measures and resource use measures in future rulemaking.

Additionally, CMS proposes establishing a 30-day all-cause, all-condition hospital readmission quality measure that will be used in a new SNF Value-Based Purchasing (VBP) Program beginning with FY 2019, as required by the Protecting Access to Medicare Act of 2014 (PAMA). CMS notes that PAMA also requires CMS to specify an all-condition, risk-adjusted potentially preventable hospital readmission rate, which CMS intends to address in future rulemaking. CMS also seeks comments on numerous issues associated with the SNF VBP Program, which will be addressed in the FY 2017 SNF PPS proposed and final rules. In addition, the proposed rule would establish new regulatory reporting requirements for SNFs and nursing facilities to electronically submit staffing information based on payroll data, as mandated by the Affordable Care Act (ACA).

Comments on the proposed rule will be accepted until June 15, 2015.

CMS Proposes Updates to EHR Meaningful Use Rules

CMS published a proposed rule on April 15, 2015 that would modify the Medicare and Medicaid Electronic Health Record (EHR) Incentive program to reduce complexity, simplify reporting requirements, and align Stage 1 and Stage 2 objectives and measures with Stage 3. Notably, CMS proposes to change the Medicare and Medicaid EHR Incentive Program reporting period in 2015 for all eligible professionals, eligible hospitals, and critical access hospitals (regardless of prior participation) to a 90-day period aligned with the calendar year. According to CMS, this 90-day EHR reporting period for 2015 would give providers more time to address any remaining issues with implementation of technology certified to the 2014 Edition and to accommodate the changes to the objectives and measures of meaningful use included in the proposed rule. CMS also proposes that EPs, eligible hospitals, and CAHs demonstrating meaningful use for the first time may use a 90-day EHR reporting period during calendar year 2016, but returning participants would use an EHR reporting period of the full calendar year 2016. In 2017, all providers would use an EHR reporting period of one full calendar year (with a limited exception for Medicaid providers demonstrating meaningful use for the first time).

In addition, CMS proposes that beginning with an EHR reporting period in 2015, providers would no longer be required to attest to certain objectives and measures that are redundant or "topped out." CMS also proposes various changes to individual objectives and measures for Stage 2 of meaningful use, beginning with the EHR reporting period in 2015. CMS will accept comments on the rule until June 15, 2015.  

CMS Proposes 1.7% Increase in Medicare IRF PPS Payments for FY 2016

On April 23, 2015, CMS released its proposed rule to update Medicare prospective payment system (PPS) rates for inpatient rehabilitation facilities (IRFs) for FY 2016, which begins October 1, 2015. CMS estimates that rates would increase by 1.7% overall ($130 million) under the proposed rule compared to FY 2015 levels. This proposed increase reflects a 2.7% market basket update (using a proposed new IRF-specific market basket) that is reduced by a 0.6 percentage point multi-factor productivity adjustment and an additional 0.2 percentage point reduction required by the Affordable Care Act, with an additional 0.2% decrease resulting from an update to the outlier threshold.

CMS proposes to revise quality measures and reporting requirements under the IRF quality reporting program, including adopting measures to satisfy the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). Specifically, CMS is proposing to adopt measures in the following three domains for FY 2016: (1) skin integrity and changes in skin integrity; (2) incidence of major falls; and (3) functional status, cognitive function, and changes in function and cognitive function. The reporting of data for these measures would affect the payment determination for FY 2018 and subsequent years. These measures are also being implemented for long-term care hospitals, skilled nursing facilities, and home health agencies. CMS also is proposing other IRF quality provisions, including implementing public reporting of IRF quality data beginning in 2016 and temporarily suspending a current quality data validation policy. In addition, the proposed rule would phase in revised wage index changes. CMS is not proposing changes to the facility-level adjustment factors for FY 2016; CMS will maintain the facility-level adjustment factors at FY 2014 levels.  The official version of the proposed rule will be published on April 27, 2015, and comments will be accepted until June 22, 2015.

CMS Proposes Mental Health Parity Rules for Medicaid Managed Care/Alternative Benefit Plans, CHIP Coverage

CMS has published a proposed rule that would apply provisions of the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to Medicaid beneficiaries who receive services through managed care organizations or alternative benefit plans and to the Children’s Health Insurance Program (CHIP). In general, such programs will be required to meet the mental health and substance use disorder benefits parity requirements regarding financial and quantitative and nonquantitative treatment limitations consistent with regulation applicable to private insurers. CMS also proposes to require such plans to make available upon request to beneficiaries and contracting providers the criteria for medical necessity determinations with respect to mental health and substance use disorder benefits. The proposed rule also would require the state to make available to the enrollee the reason for any denial of reimbursement or payment for services with respect to mental health and substance use disorder benefits. The proposed rule was published on April 10, 2015, and comments are due by June 9, 2015.

CMS Proposes Extension of Enhanced Funding for Certain Medicaid Eligibility & Enrollment Systems

On April 16, 2015, CMS published a proposed rule that would revise the definition of Medicaid mechanized claims processing and information retrieval systems to include Medicaid eligibility and enrollment (E&E) systems, which would make enhanced federal financial participation (FFP) available for such systems on an ongoing basis (current regulatory authority for such enhanced funding expired December 31, 2015). The proposed rule would set forth standards and conditions for qualifying for this enhanced funding. According to CMS, the proposed rule “would allow states to improve customer service and support the dynamic nature of Medicaid eligibility, enrollment, and delivery systems.” CMS will accept comments on the proposed rule through. June 15, 2015.

HHS Publishes Proposed Stage 3 EHR Incentive Program, Health IT Certification Rules

On March 30, 2015, the Centers for Medicare & Medicaid Services (CMS) published its proposed rule on Stage 3 meaningful use criteria, which focus on the advanced use of Electronic Health Record (EHR) technology to promote improved outcomes for patients. The proposed rule would establish the requirements that eligible professionals (EPs), eligible hospitals, and critical access hospitals must achieve to demonstrate meaningful use, qualify for Medicare and Medicaid EHR Incentive Program incentive payments, and avoid downward Medicare payment adjustments. CMS generally intends for the proposed changes to respond to provider concerns regarding the burden associated with the number of program requirements, the multiple stages of program participation, and the timing of EHR reporting periods. 

Notably, while CMS had previously announced that Stage 3 would begin in 2017, CMS is making Stage 3 compliance optional for 2017. Instead, beginning in 2018 all providers would report on the same definition of meaningful use at the Stage 3 level regardless of their prior participation. The proposed rule also would reduce the overall number of meaningful objectives to eight to focus on advanced use of EHRs (Protect Patient Health Information, Electronic Prescribing (eRx), Clinical Decision Support (CDS), Computerized Provider Order Entry (CPOE), Patient Electronic Access to Health Information, Coordination of Care through Patient Engagement, Health Information Exchange (HIE), and Public Health and Clinical Data Registry Reporting). In addition, CMS would align clinical quality measure reporting with other CMS quality reporting programs that use certified EHR technology (e.g., the Hospital Inpatient Quality Reporting and Physician Quality Reporting System programs), enhance alignment across care settings, and remove measures that are redundant or topped out. 

CMS expects net incentive payment spending under the Medicare and Medicaid EHR Incentive Programs to total $3.7 billion between 2017 and 2020 (which reflects $0.8 billion in negative payment adjustments for Medicare providers who do not achieve meaningful use). The comment period ends on May 29, 2015.

In a related development, on March 30 the Office of the National Coordinator for Health Information Technology (ONC) published a proposed rule to establish the 2015 edition health information technology certification criteria, establish a new 2015 Edition Base EHR definition, and modify the ONC Health Information Technology (IT) Certification Program to make it more broadly applicable to other types of health IT health care settings and programs. Among other things, the rule would: (1) adopt new and updated vocabulary and content standards for the structured recording and exchange of health information; (2) include enhanced data portability, transitions of care, and application programming interface capabilities in the 2015 Edition Base EHR definition; (3) align certification criteria with proposals for Stage 3; (4) provide certification to standards for the collection of social, psychological, and behavioral data to address health disparities; (5) provide for the exchange of sensitive health information and for the accessibility of health IT; (6) ensure all health IT presented for certification possesses the relevant privacy and security capabilities; (7) take a series of steps to improve patient safety; and (8) establish surveillance and disclosure requirements. Comments are due May 29, 2015.

CMS Publishes Update to DME Items Subject to Face-to-Face Encounter, Written Order Prior to Delivery Requirements

Today CMS published a notice updating the Healthcare Common Procedure Coding System (HCPCS) codes on the Durable Medical Equipment (DME) List of “Specified Covered Items” that require a face-to-face encounter and a written order prior to delivery (although CMS still is delaying enforcement of the face-to-face examination – but not the detailed written order – requirement). 

By way of background, in the 2013 Medicare physician fee schedule final rule, CMS established a list of Specified Covered Items that require a written order prior to delivery and a face-to-face encounter with a physician or other specified health care professional during the 6 months prior to the written order, and the conditions for compliance.  The initial items subject to this provision included:  items that require a written order prior to delivery under the Medicare Program Integrity Manual; items that cost more than $1,000; and items identified as particularly susceptible to fraud, waste, and abuse.  CMS announced its intention to update the list through rulemaking as necessary.  Today’s notice removes two codes from the original list because they represent items that are no longer payable by Medicare:  E0457 (Chest shell) and E0459 (Chest wrap).  The updated list is available here.

CMS Publishes Corrections to 2015 Medicare Physician Fee Schedule Final Rule

CMS has published corrections to its final 2015 Medicare physician fee schedule rule. Among other things, the rule reflects a previously-announced correction to the conversion factor for the first quarter of 2015 ($35.7547), revises the April 1 – December 31, 2015 conversion factor to $28.1872 (assuming that Congress does not take action to avert this pending cut), makes numerous code-specific relative value unit corrections, and revises quality measure details. CMS is also adding regulatory text that had been inadvertently omitted regarding general supervision of non-face-to-face aspects of transitional care management services. 

CMS Proposed Rules in the Pipeline

CMS recently sent several major proposed rules to the White House Office of Management and Budget for regulatory clearance – the last step before publication in the Federal Register. OMB is reviewing proposed rules to update the skilled nursing facility, inpatient rehabilitation facility, and inpatient psychiatric facility prospective payment systems (PPS) for fiscal year (FY) 2016, and the FY 2016 acute inpatient PPS proposed rule also should be joining them in the near future. Other CMS regulations pending at OMB include proposed rules updating the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program meaningful use requirements for 2015 through 2017 and Medicaid managed care regulations.

CMS Finalizes SMART Act MSP Appeals Provisions

This post was written by Katie Hurley and Debra McCurdy.

The Centers for Medicare & Medicaid Services (CMS) has published a final rule that implements Medicare Secondary Payer (MSP) appeals provisions under the Strengthening Medicare and Repaying Taxpayers Act of 2012 (SMART Act). Specifically, the rule addresses the right of appeal and a new multilevel appeal process for liability insurance (including self-insurance), no-fault insurance, and workers’ compensation laws or plans when Medicare pursues an MSP recovery claim directly from the applicable plan. The regulations are effective on April 28, 2015; applicable plans are parties to initial determinations issued on or after April 28, 2015 where CMS pursues recovery directly from the plan. Throughout the final rule, CMS reiterates its authority to recover directly from an applicable plan regardless of any prior attempts to recover from the beneficiary or provider, underscoring the need to address MSP recovery in all personal injury settlements with Medicare beneficiaries.

CMS Finalizes 2016 ACA Marketplace Plan Benefit & Payment Parameters

The Centers for Medicare & Medicaid Services (CMS) has finalized its Affordable Care Act (ACA) Marketplace health plan payment parameters and essential benefit standards for 2016. The rule addresses numerous policies, including: allocation of risk corridors collections for 2016; recalibration of risk adjustment factors; revisions to reinsurance and cost sharing parameters; user fees for federally-facilitated exchanges; standards for qualified health plans, including quality improvement strategy and provider directory requirements; Small Business Health Options Program requirements; conditions that trigger rate review; clarification that coverage satisfying the minimum value requirement must include substantial coverage of inpatient hospital and physician services; medical loss ratio program revisions; new policies and procedures for enrollee requests for prescription drugs not included on a plan’s formulary; and establishment of the 2016 annual open enrollment period as November 1, 2015 through January 31, 2016.  The final rule will be published on February 27, 2015. A related CMS fact sheet is available here.

Final Medicare Advantage/Part D Rule for Contract Year (CY) 2016

CMS has published a final rule revising Medicare Advantage (MA) and Part D prescription drug benefit regulations for CY 2016. Among other things, the final rule:

  • Implements a statutory provision requiring MA and Part D contracts to provide the right to “timely”’ inspection and audit and allowing CMS to require MA organizations or Part D prescription drug plan (PDP) sponsors to hire an independent auditor to validate correction of CMS audit findings.
  • Establishes U.S. citizenship and lawful presence as an eligibility requirement for enrollment in MA and Part D plans (effective June 1, 2015).
  • Makes several policy changes intended to promote efficient dispensing of drugs in long-term care (LTC) facilities, including prohibiting payment arrangements that penalize the adoption of more efficient LTC dispensing techniques by prorating dispensing fees based on days’ supply or quantity dispensed, and requiring that any difference in payment methodology among LTC pharmacies incentivizes more efficient dispensing techniques.
  • Requires MA Prescription Drug (MA-PD) plans to establish and maintain a process with network pharmacies to ensure timely and accurate point-of-sale transactions and coordinate Part A, Part B, and Part D drug benefits administered by the MA PD plan.
  • Requires a sponsor’s Pharmacy & Therapeutics committee to document its process for an objective party to determine whether disclosed financial interests are conflicts of interest and management of any recusals due to conflicts.

Other provisions of the rule address, among other things, business continuity for MA organizations and PDP sponsors; codification of recent quality improvement program policies; and notification requirements related to changes to Part D plans. CMS is not finalizing a number of proposals included in the January 2014 proposed rule, including provisions that would have: lifted the protected class designation on three drug classes; required Medicare Part D sponsors to include in preferred networks any pharmacy willing to accept the sponsor’s terms and conditions; reduced the number of Part D plans a sponsor may offer; and codified CMS interpretation of the Part D non-interference clause.

CMS Issues Final 2016 Funding Methodology for ACA Basic Health Program

On February 24, 2015, CMS published its final methodology and data sources for determining federal payment amounts for states that elect to use the Basic Health Program to offer health benefits to low-income individuals otherwise eligible to purchase coverage through an Affordable Insurance Exchange/Marketplace for 2016. CMS is using the same methodology in 2016 as was established in the final 2015 payment notice, with updated values for several factors.

CMS Corrects 2015 Medicare OPPS/ASC Final Rule, Impacts Rates

Today CMS published a notice correcting its November 10, 2014 final rule updating the Medicare Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC) Payment System rates and policies for calendar year 2015. In addition to fixing various technical errors (e.g., status indicator and addenda corrections for specific codes), the notice increases the OPPS conversion factor from $74.144 to $74.173, which will slightly increase payment rates for most ambulatory payment classifications. On the other hand, CMS is reducing the 2015 ASC conversion factor slightly, from $44.071 to $44.058. 

CMS Needs More Time to Finalize ACA Rule on Return of Medicare Overpayments

CMS warns requirement to report/return overpayments is in effect even without regulations

The Centers for Medicare & Medicaid Services (CMS) needs more time to finalize its February 16, 2012 proposed rule on reporting and returning of Medicare overpayments, according to a CMS notice to be published on February 17, 2015. The 2012 rule would provide details on implementation of an Affordable Care Act (ACA) provision requiring enrolled providers and suppliers (and certain other enrollees) receiving Medicare funds to report and return Medicare overpayments by the later of 60 days after the date on which the overpayment was identified or, if applicable, the date any corresponding cost report is due. Although the requirement to refund an overpayment already exists in federal law, the proposed rule would clarify what constitutes “identification” of an overpayment, the mechanics of when and how an overpayment must be returned, and the period of time subject to repayment. CMS had received a large number of comments from providers and suppliers and their industry associations that the proposed rule’s refund reporting policies and procedures would impose significant administrative burdens.

The Social Security Act requires public notice if an agency will take more than three years to finalize a proposed rule. CMS states that “the complexity of the rule and scope of comments warrants the extension of the timeline for publication” for an additional year (until February 16, 2016). Specifically, CMS has “determined that there are significant policy and operational issues that need to be resolved in order to address all of the issues raised by comments to the proposed rule and to ensure appropriate coordination with other government agencies.” The agency warns stakeholders, however, that “even without a final regulation they are subject to the statutory requirements found in section 1128J(d) of the Act and could face potential False Claims Act liability, Civil Monetary Penalties Law liability, and exclusion from Federal health care programs for failure to report and return an overpayment.”

Older Entries

February 2, 2015 — CMS Plans Spring Rulemaking to Modify Meaningful Use Requirements

January 30, 2015 — CMS Announces New 6-Month Extension of Moratoria on Enrollment of HHAs, Ambulance Suppliers in Designated Areas

January 14, 2015 — CMS Publishes Medicare QIO Criteria

December 17, 2014 — CMS Proposes Changes to Medicare Shared Savings Program/ACO Payment Regulations

December 16, 2014 — CMS Proposes Updating Certain Medicare/Medicaid Policies to Recognize Same-Sex Marriages

December 16, 2014 — CMS Proposes 2016 ACA Marketplace Plan Benefit & Payment Parameters

December 8, 2014 — CMS Finalizes Rule to Strengthen Medicare Provider Enrollment Regulations and Permit Revocations for Patterns/Practices of Improper Claims Submissions; Defers Expanded Awards for Medicare Fraud Tipsters

December 8, 2014 — CMS Delaying Enforcement of Medicare Part D Drug Prescriber Enrollment Requirements

December 5, 2014 — CMS Announces 2015 Provider Enrollment Application Fee Amount

December 5, 2014 — CMS Adopts Changes to Medicaid DSH Rules

December 5, 2014 — CMS Publishes Corrections to Home Health PPS, DMEPOS Surety Bond Rules

December 5, 2014 — CMS to Conduct Hyperbaric Oxygen Prior Authorization Pilot Program

December 1, 2014 — CMS Extends Comment Period on Home Health COP Proposed Rule

November 20, 2014 — CMS Publishes Final 2015 Medicare Physician Fee Schedule Rule for 2015

November 20, 2014 — CMS Finalizes CY 2015 Medicare OPPS/ASC Rates & Policies

November 20, 2014 — CMS Adopts Major Changes to Medicare DMEPOS Payment/Coverage Policy Inside/Outside of Competitive Bidding Areas

November 20, 2014 — CMS Finalizes 0.3% Cut in Medicare Home Health PPS Rates for CY 2015

November 20, 2014 — CMS Publishes Final 2015 ESRD PPS Rule

November 19, 2014 — CMS Adopts Changes to Open Payments/Physician Payment Sunshine Act Regulations

November 19, 2014 — CMS Announces 3-State Medicare Prior Authorization Model for Repetitive Nonemergent Ambulance Transport

October 28, 2014 — Final CY 2015 Medicare Payment Rules in the Pipeline

October 28, 2014 — CMS Seeking Nominations for New Advisory Panel on Clinical Diagnostic Lab Tests

October 28, 2014 — CMS Proposes 2016 Funding Methodology for ACA Basic Health Program

October 28, 2014 — CMS Announces Medicare Deductible, Coinsurance Amounts for 2015

October 17, 2014 — OIG and CMS Extend Fraud/Abuse Waivers for Medicare Shared Savings Program/ACOs; Invite Feedback on Waiver Policy

October 8, 2014 — Proposed Revisions to Home Health Conditions of Participation

October 6, 2014 — CMS Corrects Final FY 2015 Medicare IPPS/LTCH Rule

October 6, 2014 — CMS Releases CY 2015 Amount in Controversy Thresholds for Medicare Appeals

September 4, 2014 — CMS Finalizes ACA Marketplace Eligibility Redetermination/Renewal Process for 2015

August 20, 2014 — CMS Finalizes Medicare Hospice Payment Policies for FY 2015

August 19, 2014 — CMS Issues FY 2015 Medicare SNF PPS Final Rule

August 18, 2014 — CMS Finalizes Medicare IPPS/LTCH PPS Update for FY 2015

August 18, 2014 — CMS Publishes Final FY 2015 Update to Medicare IRF PPS

August 12, 2014 — CMS Issues Final Medicare Inpatient Psychiatric Facility PPS Rule for FY 2015

August 12, 2014 — CMS Again Extends Moratoria on Enrollment of HHAs, Ambulance Suppliers in Designated Areas

July 25, 2014 — CMS Issues Proposed CY 2015 Medicare OPPS/ASC Rule

July 25, 2014 — CMS Publishes Proposed MPFS Rule for 2015

July 25, 2014 — CMS Proposes ESRD PPS Update for CY 2015

July 7, 2014 — CMS Proposes Major Changes to Medicare DMEPOS Payment/Coverage Policy Inside/Outside of Competitive Bidding Areas

July 3, 2014 — CMS Proposes Changes to Sunshine Act "Open Payments" Regulations in 2015 Medicare Physician Fee Schedule Rule

July 1, 2014 — CMS Proposes 0.3% Cut in Medicare Home Health PPS Rates for CY 2015

June 27, 2014 — CMS Planning Changes to Medicare Shared Savings Program/Accountable Care Organization (ACO) Rules

June 24, 2014 — Medicare Payment Adjustments for Low-Volume Hospitals and Medicare-Dependent Hospitals

June 2, 2014 — CMS Finalizes Updates to Medicare Advantage/Part D Policies for 2015

June 2, 2014 — CMS Finalizes ACA Exchange, Insurance Market Standards for 2015 and Beyond

May 30, 2014 — CMS Formally Proposes Modified Electronic Health Record (EHR) Meaningful Use Timeline

May 22, 2014 — CMS Proposes Medicare Prior Authorization Process for DMEPOS Subject to "Unnecessary Utilization"

May 15, 2014 — CMS Adopts Final Rule to Reduce Provider Regulatory Burdens

May 15, 2014 — CMS Proposes Medicare Hospice Payment Policies for FY 2015

May 15, 2014 — CMS Proposes FY 2015 Update to Inpatient Psychiatric Facility PPS

May 15, 2014 — CMS Adopts PPS for Federally Qualified Health Centers (FQHCs), Amends CLIA Rules

May 14, 2014 — CMS Proposes FY 2015 Update to Medicare IRF PPS

May 13, 2014 — CMS Invites Comments on Sunshine Act "Open Payments" Dispute Resolution/Corrections Process

May 13, 2014 — CMS Issues FY 2015 Medicare SNF PPS Proposed Rule

May 8, 2014 — CMS Streamlines Medicare Requirements for Imaging Services Performed in ASCs and Hospital Radiopharmaceutical Preparation

May 1, 2014 — CMS Releases Proposed Medicare Inpatient PPS/LTCH Update for FY 2015

April 28, 2014 — Proposed FY 2015 Medicare Payment Rules in the Pipeline

April 28, 2014 — CMS Proposes Updated Life Safety Code for Health Care Facilities

April 8, 2014 — RACs Correct $2.4 Billion in Medicare Claims in FY 2012

April 8, 2014 — CMS Announces System to Collect Hospice Care Data Beginning July 1, 2014

March 24, 2014 — Obama Administration Continues to Update ACA Insurance Exchange and Health Plan Regulations

March 20, 2014 — CMS Rule Increases FY 2014 Medicare Payments for Low-Volume Hospitals

March 19, 2014 — CMS Rule Requires Qualified Health Plans to Accept Certain Third-Party Premium Payments

March 4, 2014 — Preliminary FY 2014 DSH Allotments Announced

March 3, 2014 — CMS Takes First Steps to Cut Medicare DMEPOS Fees Based on Competitive Bidding Prices

February 18, 2014 — CMS Extends and Expands Moratoria on Enrollment of Home Health Agency, Ambulance Suppliers in Designated Areas

February 17, 2014 — CMS Seeks New Participants for Bundled Payments for Care Improvement Initiative

February 11, 2014 — CMS Invites Proposals for Frontier Community Health Integration Demonstration

January 30, 2014 — CMS Finalizes Rule to Strengthen Home- and Community-Based Services (HCBS) Options

January 29, 2014 — Reed Smith Client Alert: CMS/OIG Extend Protections for Electronic Health Record Donations

January 8, 2014 — CMS Proposes Updates to Medicare Advantage/Part D Policies for 2015

January 7, 2014 — CMS Proposes Emergency Preparedness Requirements for Medicare/Medicaid Providers

January 7, 2014 — CMS, FDA Extend Pilot Program for Parallel Review of Medical Products

January 7, 2014 — CMS Proposes 2015 Funding Methodology for ACA Basic Health Program

January 7, 2014 — CMS Issues Formally Updates 2014 Health Exchange Enrollment Deadlines

January 6, 2014 — CMS Seeks Comments on MSP CMP Policies, Appeals Process

December 27, 2013 — Final Rules Issued Extending Protections of Electronic Health Record Donations

December 10, 2013 — CMS Issues Final Medicare OPPS, ASC Policies for 2014

December 10, 2013 — CMS Updates Medicare Physician Fee Schedule, Other Part B Policies for CY 2014

December 10, 2013 — CMS Finalizes 2014 ESRD PPS Rates; Phases in ESRD Drug Utilization Cut

December 10, 2013 — CMS Proposed Rule on ACA Benefit and Payment Parameters for 2015

December 10, 2013 — CMS Boosts Provider Enrollment Fee for 2014

December 3, 2013 — CMS Adopts Changes to Medicare Payment, Coverage Rules for DMEPOS

November 25, 2013 — Medicare Home Health PPS Rates Cut 1.05% Under Final 2014 Rule

November 25, 2013 — CMS Seeks Input on Quality Ratings for ACA Exchange Plans

November 14, 2013 — CMS Invites Nominees for Members of Advisory Panel on Hospital Outpatient Payment

October 30, 2013 — CMS Finalizes ACA Exchange Program Integrity & Financial Oversight Standards

October 30, 2013 — CMS Releases Medicare Deductible, Coinsurance Amounts for 2014

October 30, 2013 — CMS Warns of Delay in Final CY 2014 Medicare Rules

October 29, 2013 — CMS Finalizes Medicare Conditions of Participation for Community Mental Health Centers

October 10, 2013 — HHS Proposes ACA Basic Health Program Regulations

October 10, 2013 — CMS Final Rule Refines FY 2014 DSH Payment Calculations

October 10, 2013 — CMS Proposes Rules for Medicare FQHC PPS, CLIA Amendments

October 9, 2013 — CMS Announces 2014 Amounts in Controversy Threshold Amounts for Medicare Appeals

October 9, 2013 — CMS Corrects FY 2014 Medicare Payment Rules

September 17, 2013 — CMS Finalizes ACA Exchange/Qualified Health Plan Financial Integrity and Oversight Standards

September 16, 2013 — CMS Releases ACA Medicaid DSH Funding Final Rule

September 11, 2013 — CMS Issues Technical Corrections to CY 2014 Proposed OPPS/ASC Rule

September 3, 2013 — Recent Updates to the Hospital Readmissions Reduction Program

August 28, 2013 — CMS Finalizes FY 2014 Medicare IPPS, LTCH Rates