Posted by Danielle Sapega
on November 19, 2019
CMS /
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CMS
finalized the Outpatient Prospective Payment System hospital price transparency
rules on November 15, 2019. As of January 1, 2021, hospitals will have to
publicly post (and update annually) two sets of data: first, a comprehensive
list of standard charges for items services offered by the hospital, and
second, a consumer-friendly list of 300 “shoppable” services, including 70
selected by the Centers for Medicare and Medicaid Services (“CMS”).
The first
transparency requirement states that each hospital operating within the United
States must establish and make public a list of the hospital’s standard charges
for items and services provided by the hospital, including diagnosis-related
groups (DRGs). Standard charge is defined as “the regular rate established by
the hospital for an item or service provided to a specific group of paying
patients. This includes: (i) gross charge, (ii) payer-specific negotiated
charge, (iii) de-identified minimum negotiated charge, (iv) de-identified
maximum negotiated charge, and (v) discounted cash price.” Items and services
is defined as “all items and services, including individual items and services
and service packages, that could be provided by a hospital to a patient in connection
with an inpatient admission or an outpatient department visit for which the
hospital has established a standard charge.” Examples include supplies and
procedures and room and board.
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Posted by Danielle Sapega
on June 24, 2019
CMS /
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CMS recently issued long-awaited draft guidance on hospital co-location with other hospitals or healthcare facilities, providing some potential insight on the otherwise ambiguous prohibition on “shared space.” This prohibition loosely stems from the requirement that a Medicare participating hospital is evaluated “as a whole” for compliance with the Conditions of Participation (“CoP”), among other state and federal regulatory requirements. Previously, it was believed that the provider based regulations at 42 C.F.R. § 413.65 governed this prohibition (this section was cited in a 2016 memorandum from the Pennsylvania Department of Health), but the CMS guidance did not cite this particular section.
In recent years, CMS has started to crack down on provider based hospital departments that physically share space with non licensed or separately owned hospital facilities, generally prohibiting shared staff, waiting rooms, check-in desks, patient bathrooms, and other similar items and costs. Although the prohibition was not absolute (CMS had permitted certain things to be shared, such as staff lounges and shared main lobbies), hospitals that sought to attain and maintain compliance struggled with the lack of clear guidance from CMS, and had to rely largely on word of mouth, occasional information distributed by State Survey Agencies, or even citations received if the hospital was caught with prohibited shared space or staffing. This was especially troubling in light of the fact that remediation potentially involved large scale, expensive construction and a hiring and staffing model revamp, among other mandatory modifications.
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Posted by Danielle Sapega
on June 07, 2019
Pennsylvania /
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In 2018,
Governor Tom Wolf signed a multitude of bills into law that significantly
impact Pennsylvania health care providers. Compliance deadlines for these new
laws vary. Implementing any new policies or procedures often takes longer than
anticipated, so we strongly recommend taking steps to determine whether your
organization is out of compliance. While not all-encompassing, the following
laws represent those of particular significance:
Act 90 – Anatomical Gifts: this act represents
a significant update to Pennsylvania’s anatomical gift law. Additions include a
new section addressing specific requirements around vascularized composite
allograft donation, an update to the statutory list of designated health care
representative decision makers, and new medical record documentation
requirements.
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