Health Law Matters

Showing 4 posts by Rhonda Frey.

Is ‘incident to’ billing for Medicare going . . .going . . . gone?

The Medicare Payment Advisory Commission (MedPAC) recommended to Congress in its June 2019 report that ‘incident to’ billing be eliminated. In response to MedPAC’s biennial reports, Congress normally holds hearings to listen to MedPAC’s commissioners and staff and then decide whether any legislation should be introduced based on the recommendations. Some recommendations are embraced while others are simply disregarded. But, given the government’s current focus on saving money for Medicare, this recommendation is not likely to be ignored. Read More ›

CMS’s "Fresh Look” at Space Sharing Looks All Too Familiar.”

Hold the presses – CMS’s long-awaited guidance on shared space arrangements between hospitals and other entities is here. But it appears that the new guidance wasn’t worth the wait. If you are a hospital or other health care entity who has been standing by in hopeful anticipation of CMS’s “fresh look” at shared space arrangements, you will be sorely disappointed.  Read More ›

To Share or Not to Share (Space) – That is STILL the Question

As we rapidly approach the fifth month of the year, the Center for Medicare and Medicaid Services (CMS) has yet to issue its much-awaited “fresh look” guidance on shared space arrangements between hospitals and other entities, such as physician practices and ambulatory surgery centers. David Wright, deputy director of CMS’s Center for Clinical Standards and Quality, talked about CMS’s new direction at the American Health Lawyers Association (AHLA) conference in March 2018 and again during an AHLA webinar in November, indicating that the guidance was in the final stages of development and could be released any day.[1] But so far, nothing. Read More ›

CMS Backs Off (a little!) in Finalizing the 2019 OPPS Rule

Health care charts

The long-awaited 2019 Hospital Outpatient Prospective Payment System (OPPS) final rule has arrived – and it came with at least one surprise. The Centers for Medicare and Medicaid Services (CMS) elected NOT to finalize the rule pertaining to the “clinical family of services” at Provider Based Departments (PBD). Read More ›

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Attorney Spotlight

Brian F. Higgins is an associate in FBT's regulated business group with a focus on health care, and he has a history as corporate counsel to Medpace, Inc., a pharmaceutical clinical research organization.