what wE KNOW.
Our team regularly assists providers in making sense out of one of the most challenging areas of health care.
September 2022
Updates:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
February 2022
Updates:
Health Care Reimbursement and Payor Dispute Update Special Edition - Year End Regulatory Review
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
October 2021
UPDATES:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
June 2021
webinars:
Reimbursement for Innovation in Behavioral Health Care
Thursday, June 3
12:00 PM - 1:00 PM CDT
As behavioral health care needs and costs escalate, providers, patients and payors alike are looking for ways to provide high-quality service to broader populations, while also reducing costs. The industry is looking to technological advancements, new models of care, and new reimbursement strategies to reinvent behavioral health care delivery.
Click here to register.
May 2021
UPDATES:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
February 2021
UPDATES:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
webinars:
5th Annual Health Care Reimbursement Summit - Part 1
Tuesday, February 23
9:00 AM - 12:00 PM CST
We are pleased to announce that we will be presenting our 5th Annual Health Care Reimbursement Summit as a two-part virtual series. Join Polsinelli Reimbursement Institute and others in the health care finance, reimbursement, compliance and legal world to get in-depth and timely information focused exclusively on Medicare, Medicaid and commercial reimbursement issues.
This webinar was previously recorded. To view a recording of this webinar, click here. To access the materials from this webinar, click here.
5th Annual Health Care Reimbursement Summit - Part 2
Thursday, February 25th
9:00 AM - 12:00 PM CST
We are pleased to announce that we will be presenting our 5th Annual Health Care Reimbursement Summit as a two-part virtual series. Join Polsinelli Reimbursement Institute and others in the health care finance, reimbursement, compliance and legal world to get in-depth and timely information focused exclusively on Medicare, Medicaid and commercial reimbursement issues.
This webinar was previously recorded. To view a recording of this webinar, click here. To access the materials from this webinar, click here.
December 2020
UPDATES:
Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
October 2020
UPDATES:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
September 2020
WEBINARS:
Health Care Reimbursement Conundrums Webinar Series: Part 2 - Commercial Payors
Wednesday, September 16
12:00 PM - 1:00 PM CST
As COVID-19 continues to plague the health care industry and the economy, money is tight and making sure you are collecting and keeping every dollar due is paramount. Polsinelli’s Reimbursement Institute team will help health care entities strategize about challenges and priorities for providers to focus on during the COVID-19 period, including reimbursement for COVID-19 related services, resolving past underpaid and denied claims, and addressing commercial payor refund and recoupment efforts. Presenters will identify current priorities and provide specific examples on how to navigate these issues in order to maximize providers’ commercial payor reimbursement. This webinar is meant for finance and revenue cycle executives, and the legal and compliance teams that support them.
This webinar was previously recorded. To view a recording of this webinar, click here. To access an audio only version of this webinar, click here. To access the materials from this webinar, click here.
August 2020
UPDATES:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
WEBINARS:
Health Care Reimbursement Conundrums Webinar Series: Part 1 - Government Payors
Thursday, August 27
12:00 PM - 1:00 PM CST
As COVID-19 continues to plague the health care industry and the economy, money is tight and making sure you are collecting and keeping every dollar due is paramount. Polsinelli’s Reimbursement Institute team will help health care entities strategize about common billing, collections and audit issues in order to help limit recoupments and refunds, while effectively appealing denied or short-pay claims. Presenters will provide specific examples on how to navigate these issues in order to maximize your entity’s government reimbursement. This webinar is meant for finance and revenue cycle executives, and the legal and compliance teams that support them.
This webinar was previously recorded. To view a recording of this webinar, click here. To access an audio only version of this webinar, click here. To access the materials from this webinar, click here.
June 2020
WEBINARS:
Strategies for Post-COVID Commercial Payor Reimbursement Planning
Thursday, June 11
12:00 PM - 1:00 PM CST
Part 2 of the Provider Challenges and Opportunities with Commercial Payors in the COVID and Post-COVID World series, this webinar will focus on health care provider opportunities to resolve claims backlog and to anticipate and plan for reimbursement and contracting in the post-COVID environment.
This webinar was previously recorded. To view a recording of this webinar, click here. To access the materials, click here.
May 2020
WEBINARS:
Current Issues with COVID-19 Commercial Reimbursement
Wednesday, May 27
12:00 PM - 1:00 PM CST
Part 1 in the Provider Challenges and Opportunities with Commercial Payors in the COVID and Post-COVID World series, this webinar will focus on commercial reimbursement issues affecting healthcare providers caring for patients with known or suspected exposure to COVID-19. The panel will summarize new federal laws that apply to commercial reimbursement, unique questions that have arisen, and state regulatory guidance designed to assist providers.
To view a recording of the webinar, click here. To access the materials from this webinar, click here.
February 2020
UPDATES:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
WEBINARS:
Introduction to Commercial Health Care Reimbursement and Contracting
Wednesday, February 5
12:00 PM - 1:00 PM CST
Join Polsinelli Healthcare Solutions attorneys for a complimentary webinar discussing the commercial healthcare reimbursement landscape, the role of contracting between payers and providers, and common landmines in the contracting process.
This webinar was previously recorded. To view a recording of this webinar, click here.
January 2020
UPDATES:
2020 To-Do List: Health Plan Performance Report Card
A turn of the calendar brings us to a new decade, which means new relationships for health care providers or the continuation of long-standing contracts with health plans. It also means new opportunities to evaluate and monitor these relationships, and more importantly, the effectiveness of their performance. If you cannot readily identify key performance metrics for each major health plan relationship, it is time to develop a Payor Report Card in 2020.
WEBINARS:
Introduction to Government Health Reimbursement
Thursday, January 30
12:00 PM - 1:00 PM CST
Join Polsinelli for a complimentary webinar discussing the basics of Medicare and Medicaid reimbursement. We recommend this session to members of health care entities’ general counsel, operations, finance/accounting, or executive teams who are new to health care, or would like a refresher course on how key government payers work.
This webinar was previously recorded. To view a recording of the webinar, click here.
December 2019
Updates:
Remote Patient Monitoring Opportunities and Risks for Technology Vendors and Providers
In recent years, the Centers for Medicare and Medicaid Services (CMS) has expanded coverage for remote patient monitoring (RPM) services under Medicare. RPM services include establishing, implementing, revising, and monitoring a specific patient treatment plan related to one or more chronic conditions. RPM may be used to promote proactive patient self-care, monitor patients’ key measures, and allow providers and patients easy access to information about patient health issues.
On October 31, 2019, the Office of General Counsel for the U.S. Department of Health and Human Services (HHS) issued an important memo from Kelly M. Cleary, CMS Chief Legal Officer, and Brenna E. Jenny, Deputy General Counsel, discussing the impact of the recent U.S. Supreme Court ruling Azar v. Allina Health Services, 139 S. Ct. 1804 (2019) on enforcement actions brought by the government (“Cleary Memo”). A copy of the Cleary Memo is available here.
November 2019
updates:
CMS Issues New Final Rule on Pricing Transparency
On November 15, CMS issued the Price Transparency Requirements for Hospitals to Make Standards Charges Public Final Rule (“Final Rule”), as directed by President Donald Trump’s Executive Order on Improving Price and Quality Transparency in American Healthcare and as originally authorized by Section 2718(e) of the Public Health Service Act (“PHS Act”). The Final Rule is effective January 1, 2021.
Late last week, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment System (“OPPS”) final rule [CMS-1717-FC] (display copy available here). While many hospitals had hoped for relief from recent OPPS payment cuts and for clarity on the scope of the price transparency mandate, CMS offers neither in this final rule. The only bright spot is the significant change to the physician supervision requirement for hospital outpatient therapeutic services, which, as of January 1, 2020, will permit general supervision across the board. This alert addresses these issues as well as several ancillary policies finalized by CMS.
October 2019
updates:
Health Care Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
WEBINARS:
Reimbursement Trends and Strategies - Keys To Your Financial Success
In this webinar we explore government and private reimbursement trends, highlights and strategies across the spectrum of hospital-based and freestanding behavioral health providers - including the impact of recent legislation related to the Opioid epidemic. Additionally, we discuss the impact of parity laws on reimbursement for mental and behavioral health services and analyze strategies for providers when plans are out of compliance with parity laws.
This webinar was previously recorded. To view the recorded version of this webinar, click here.
August 2019
updates:
2020 Medicare Physician Fee Schedule - Reimbursement and Payment Policy Proposals
On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) released the FY 2020 Medicare Physician Fee Schedule (MPFS) proposed rule [CMS-1715-P] (Proposed Rule). A link to the full rule is available here. Stakeholder comments on the rule are due no later than 5:00 pm ET on Friday, September 27, 2019. Because CMS released the proposed 2020 MPFS Proposed Rule later than in prior years and must publish a final rule by early November 2019, many stakeholders plan to submit prior to the deadline in order to give the Agency time to duly consider their suggestions and concerns.
View the full update here.
CMS Takes Bold Action on Price Transparency & Physician Supervision in CY 2020 OPPS Proposed Rule
On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment Systems (“OPPS”) proposed rule [CMS-1717-P] (display copy available here). In addition to the customary payment adjustments, the highlights of this year’s proposed rule are two policies with significant implications: (1) a broad price transparency policy, requiring hospitals to publish extensive charge and payment rate information; and (2) a proposal to reduce the required level of physician supervision from direct to general for hospital outpatient therapeutic services in all hospitals. This alert will focus on these policies and also address a series of ancillary proposals appearing in the 800+ page display copy of the proposed rule. The rule will be published in the Federal Register on August 9, 2019.
CY 2020 OPPS Proposed Rule – HHS Seeks Comments on 340B Payment Reductions and Remedies
This past week, CMS confirmed it will continue the 2018 and 2019 underpayment policy for certain 340B covered entities unless the D.C. Court of Appeals upholds the lower court’s ruling that it is unlawful. In that case, CMS signaled its intent to implement the highest permissible payment reduction, which it appears to interpret as 3%. CMS also signaled its intent to use the Administrative Procedure Act (APA) to delay any corrections to the underpayment until at least CY 2021, depending on when the D.C. Court of Appeals will issue its decision.
New Settlement Program for Medicare Overpayments
Medicare providers who have overpayments with pending requests for Administrative Law Judge (ALJ) hearings filed on or before March 31, 2019 may now take advantage of the renewed Settlement Conference Facilitation (SCF) program. This program allows the providers to meet with CMS representatives to discuss the possibility of a mutually agreeable resolution of the issues now rather than having to wait for months or even years longer to have their cases heard by a judge. Moreover, this is an opportunity for providers who have already re-paid most or all of their overpayment to begin to recover some of those monies. This is the first renewal of the program since a similar one was opened to parties with hearing requests pending prior to November 2017.
JUNE 2019
updates:
Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
MAY 2019
updates:
Space Sharing Re-Boot: CMS Offers a New Approach in the State Operations Manual
On May 3, 2019, CMS published draft guidance regarding space sharing between co-located hospitals and hospitals co-located with other health care entities. This new guidance, published as an addition to Appendix A of the State Operations Manual (“SOM”), offers providers an opportunity to comment by July 2, 2019. Comments should be directed to HospitalSCG@cms.hhs.gov. CMS expects to publish final space sharing guidance following this comment period.
340B In The Spotlight – Key Program Developments
In this issue, Polsinelli’s 340B and Reimbursement teams provide an update on the most recent developments in the ongoing 340B /Part B Payment litigation and also highlight recent Government Accountability Office (“GAO”) interest in covered entities duplicate discount prevention efforts.
MARCH 2019
updates:
340B In The Spotlight – Key Program Developments
Polsinelli’s 340B and Reimbursement teams continue to closely monitor several key developments impacting 340B covered entities. There has been a flurry of federal and state developments in the past few weeks that may have significant implications on covered entities.
FEBRUARY 2019
updates:
Reimbursement and Payor Dispute Update
Polsinelli is pleased to share the Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
View the full newsletter here.
WEBINARS:
Reimbursement Institute - Intro to Health Care Reimbursement
Understanding government and commercial payors work is a fundamental building block for understanding strategy, business, and ultimately, success in the health care industry. Our team guides you through the key components of the major government and commercial plans.
This webinar was previously recorded. To view a recorded version of this webinar, please click here.
JANUARY 2019
updates:
8th Circuit Ruling Impacting Commercial Payer Practices
After over a year of waiting, The Eight Circuit Court of Appeals aligns itself with the Department of Labor in determining that the practice of Cross-Plan Offsetting orchestrated by many commercial health insurance companies, and in this case United Healthcare, to recover erroneously overpaid claims from out-of-network health care providers is not only a violation of the terms of a self-funded benefit plan, but may also trigger additional liabilities for commercial health insurers and plan sponsors and administrators of self-funded benefit plans under ERISA.
The Path Forward - Big Decisions Ahead for ACOs under MSSP Final Rule
The December 21, 2018 “Pathways to Success” final rule governing Accountable Care Organizations participating in the Medicare Shared Savings Program (MSSP) will require expedited migration to financial risk arrangements.
Federal Judge Overturns Part B Payment Cuts to the 340B Drug Discount Program
A federal district court granted a permanent injunction against the Medicare Part B 2018 Outpatient Prospective Payment System (“OPPS”) payment cuts for separately payable, non-pass through drugs purchased through the 340B Drug Discount Program.
DECEMBER 2018
updates:
CMS Makes Changes to MSSP in 2019 Physician Fee Schedule
In the 2019 Medicare Physician Fee Schedule (MPFS) final rule published on November 23, CMS published new policies for accountable care organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP).
NOVEMBER 2018
updates:
The Medicare Physician Fee Schedule for 2019
On November 1, 2018, the Centers for Medicare & Medicaid Services (“CMS”) released an advanced copy of the final rule announcing policies and payment levels for the Medicare Physician Fee Schedule for 2019, implementing policy changes to the Quality Payment Program (“QPP”), and announcing other miscellaneous payment policies for Medicare Part B items and services.
AUGUST 2018
Speaking Announcements/Presentations:
Polsinelli Shareholder Cybil G. Roehrenbeck to Present at Center for Rural Health Annual Meeting
Polsinelli is proud to announce that Shareholder Cybil G. Roehrenbeck is a featured presenter at the 2018 Georgia Hospital Association's Center for Rural Health Annual Meeting. The conference schedule features abundant educational and networking opportunities with experienced professionals in the health care industry.
JULY 2018
updates:
CMS Targets Off-Campus Provider-Based Departments in 2019 OPPS Proposed Rule
On Wednesday July 25, 2018, the Centers for Medicare and Medicaid Services (CMS) released an advance copy of the CY 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule.
Be Prepared: Provider-Based Mid-Build Audits Are Here
Hospitals with off-campus provider-based departments (“PBDs”) under construction (or “mid-build”) at the time of the Bipartisan Budget Act of 2015 – which limited Medicare payment to off-campus provider-based departments that were not operational prior to November 2, 2015– have been waiting years for Medicare to confirm the provider-based status of these locations.
APRIL 2018
updates:
Fifth Circuit Grants Health Care Providers Medicare Appeals Backlog Remedy
A recent ruling allows health care providers to seek relief from federal courts if the delay caused by the Medicare appeals backlog is likely to cause the provider irreparable injury.
Speaking Announcements/Presentations:
Polsinelli's Burris, Niecko-Najjum, Peters, and Vasquez to Present at HCCA Compliance Institute
Polsinelli is proud to announce that Shareholders R. Ross Burris, III, Iliana L. Peters, Kyle A. Vasquez, and Associate Lidia M. Niecko-Najjum are featured presenters at the 2018 Compliance Institute, hosted by the Health Care Compliance Association.
MARCH 2018
updates:
Continuing Resolution Creates Significant Changes to Medicare and Medicaid Policies
The Bipartisan Budget Act of 2018, commonly referred to as the “Continuing Resolution,” was recently signed into law, creating a short-term fix to funding the federal government for six weeks while also raising the debt ceiling for one year and increasing spending limits for two years.
JANUARY 2018
updates:
Gainsharing Guidance: Clarification on Cost-Savings Arrangements Between Hospitals and Physicians
The Office of Inspector General of the U.S. Department of Health and Human Services (OIG) recently posted its first advisory opinion interpreting a gainsharing arrangement – that is, a financial relationship under which providers share in cost-savings – since passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
Six Things to Know on CMS's Guidance Addressing the Low Volume Medicare Appeal Settlement
The Centers for Medicare and Medicaid Services (“CMS”) recently issued guidance that starting Feb. 5, 2018, CMS will begin the process for the Low Volume Appeal (“LVA”) settlement option that CMS had announced on Nov. 3.
NOVEMBER 2017
updates:
Year 2 in the QPP: A Regulatory Update
On November 2, 2017, the Centers for Medicare and Medicaid Services (CMS) released the 2018 Quality Payment Program (QPP) Final Rule. The Final Rule contains notable changes that may affect smaller practices participating in the Merit-based Incentive Payment System (MIPS) and clinicians’ strategic participation in Alternative Payment Models (APMs).
In its 2018 Outpatient Prospective Payment System final rule (Final Rule) issued Nov. 1, Centers for Medicare and Medicaid Services (CMS) implemented a significant Medicare Part B payment reduction for separately payable, non-pass-through drugs provided in the hospital outpatient setting. CMS also finalized several new modifiers that will present significant operational challenges, given a very short turnaround time to implement.
Publications:
Medicare Settlement Plan Could Relieve Appeal Backlog
A pair of initiatives announced recently by the Centers for Medicare & Medicaid Services could allow the agency to resolve a portion of its gargantuan Medicare administrative appeals backlog.
OCTOBER 2017
updates:
HwHs are hospitals excluded from the inpatient prospective payment system (“IPPS”), such as psychiatric, long-term care, children’s and cancer hospitals, but are located in the same building or on the same campus as another hospital (the “host hospital”).
Speaking Announcement/Presentation:
Polsinelli is proud to announce that Shareholder R. Ross Burris, III will present at the Healthcare Enforcement Compliance Institute, hosted by Health Care Compliance Association.
APRIL 2017
Speaking Announcements/Presentations:
Jeremy Burnette and Anthony Choe Present "Out-of-Network Reimbursement"
Polsinelli is proud to announce that Shareholder Jeremy Burnette and Counsel Anthony Choe will be presenting at the 2017 Emergency Department Practice Management Association (EDPMA) Solutions Summit in San Diego.
FEBRUARY 2017
updates:
Feb. 13 Deadline Looms for Provider-Based Departments Seeking Mid-Build Exception
A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build Exception).