CMS permits home dialysis in a long-term care facility (“LTCF”)—that much is clear. But that is about as much clarity as there is, and the newly released Final Prospective Payment System (“PPS”) rule for End Stage Renal Disease (“ESRD”) does not make things much better. In 2004, CMS issued two …
The Sixty Day Rule: Reporting & Returning Overpayments Under PPACA
August 13, 2010 Leave a Comment
Among numerous changes to the Medicare and Medicaid Program Integrity Provisions, Section 6402 the Patient Protection and Affordable Care Act (“PPACA”) contains urgent requirements for reporting and returning overpayments. The new provision requires certain entities – including providers, suppliers, …
New Statute Sheds Light on Three-Day Rule for Hospital Billing
August 6, 2010 Leave a Comment
On June 25, 2010, President Barack Obama signed into law the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010. Among other provisions, Section 102 of the legislation broadens the interpretation of what is known as the three-day rule, Medicare's policy for payment for …
Five Action Items for Health Care Executives and Board Members, Part Three
June 15, 2010 Leave a Comment
Putting aside hotly contested issues such as the proper scope of federal authority and the cost of expanded coverage, the new law has pragmatic implications for health care providers in five broad areas that will affect provider activity in a number of different ways. Today is the final post in the series. Five …
Five Action Items for Health Care Executives and Board Members, Part Two
June 10, 2010 Leave a Comment
Putting aside hotly contested issues such as the proper scope of federal authority and the cost of expanded coverage, the new law has pragmatic implications for health care providers in five broad areas that will affect provider activity in a number of different ways. Today is Part Two of covering the Five …