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McBrayer Blogs
Clarifying the “Two-Midnight Rule” and Part A Payments
In August, the Centers for Medicare and Medicaid Services (“CMS”) announced a final rule regarding the prospective payment for acute care and long-term care hospital inpatient services for fiscal year 2014. This rule becomes effective on October 1, 2013. More >
New IRS Guidance for Charitable Hospitals
The Patient Protection and Affordable Care Act added section 501(r) to the Internal Revenue Code, which imposes new requirements on 501(c)(3) organizations (nonprofit hospitals) that operate one or more hospital facilities. Under section 501(r), each hospital facility operated by a 501(c)(3) organization must meet four general requirements on a facility-by-facility basis in order for the nonprofit hospital to maintain its tax exempt status: More >
Nearly Two-Thirds of CAHs’ Status in Jeopardy
On August 15, 2013, the Office of the Inspector General of the Department of Health and Human Services (“OIG”) released a report entitled “Most Critical Access Hospitals Would Not Meet the Location Requirements if Required to Re-enroll in Medicare” (“Report”). If the recommendations in the Report are fully executed, it would cause a detrimental blow to rural hospitals. There are approximately 1,300 critical access hospitals (“CAHs”) currently in operation. More >
PHI May Be In More Places Than You Think
A recent HIPAA settlement serves as an important reminder that protected health information (PHI) may be stored on “ordinary” office equipment such as printers, photocopiers, scanners and fax machines, and not just on computer hard drives. On August 14, 2013, the Department of Health and Human Services (HHS) announced a settlement with the not-for-profit managed care plan Affinity Health Plan, Inc. (“Affinity”) for over $1.2 million in connection with HIPAA Privacy and Security breaches stemming from PHI stored on a photocopier hard drive. More >
Licensure Requirements for Home Medical Equipment Providers, Personal Service Agencies
It is no surprise that, given the current health care climate, providers who were unregulated just a few years ago are now subject to certification and licensure requirements. More >
Final Rule for Long-Term Care Facilities and Hospice Providers Becomes Effective August 26th
On June 27, 2013, CMS published its final rule for hospice agreements with long-term care (“LTC”) providers. LTC facilities are now required to have written agreements specifying what services the hospice and LTC provider will provide to nursing home residents receiving hospice care. This new Condition of Participation (CoP) aims to improve the quality and consistency of care between LTC and hospice providers by specifically defining responsibilities and roles. The agreement must be signed by authorized representatives for both the LTC facility and hospice before hospice care can be provided to patients. The effective date is August 26, 2013. More >
Beyond Making the Rounds: Hospitalists & Quality of Care under the ACA, cont.
On Tuesday, I discussed how hospitalists play a vital role in meeting the ACA's quality of care standards for the inpatient setting. Now, let's take a look at how PCPs must also work to meet these same standards. More >
Beyond Making the Rounds: Hospitalists & Quality of Care under the ACA
By now, everyone knows the Affordable Care Act’s (“ACA”) motto is “increase quality, decrease costs.” As providers transition from the fee for service payment model to new payment systems that are tied to quality, one subset of providers will play a pivotal role in bringing health care into a new era: hospitalists. More >
Kentucky Selected To Participate in ER “Superusers” Program
If you have ever visited an emergency room in the Commonwealth, chances are that you have seen a “superuser” – a person who uses the emergency room for regular health care instead of opting for a lower-cost alternative such as a primary care physician. Whether Medicaid recipients or uninsured, superusers (also known as “super-utilizers” or “frequent flyers”) increase Medicaid expenditures and drive up the overall costs of health care. In 2012, 4,400 Medicaid recipients used an emergency room ten or more times, and Kentucky Medicaid spent more than $219 million on emergency room use. Superusers, however, do not just waste money. They also waste the valuable time and resources of emergency room providers, creating longer wait times for those experiencing true emergencies. More >
The Pioneer Program Report Card
In 2012, thirty-two organizations were selected to participate as “Pioneers” in a pilot Accountable Care Organization (“ACO”) program created through the Affordable Care Act (“ACA”). The program’s goals were to revolutionize the health system and reduce medical costs by basing physician and hospital pay on quality rather than quantity. More >
