On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the final rule for the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS). The final rule generally remained unchanged from the proposed version. While not all of the final payment changes in the CY 2022 MPFS were well received by stakeholders, many praised rule changes made to vaccine administration payment updates and further expansion of telehealth services, allowing for greater patient access. This Health Capital Topics article will briefly review CMS’s 2022 MPFS final rule, which will go into effect on January 1, 2022, as well as its potential impacts. (Read more...)

On November 2, 2021, the CMS released the calendar year (CY) 2022 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) payment system final rule, in which the agency finalized several of the policies it proposed in July 2021. In summary, the final rule updated payment rates and addressed issues such as health equity and patient-centered care, increasing price transparency, patient safety, and access to quality care generally. This Health Capital Topics article will briefly review those major updates and changes to, as well as the possible impacts of, CMS’s 2022 final rule, which will go into effect on January 1, 2022. (Read more...)

The 2020 performance year (PY) results for two of Medicare’s accountable care organization (ACO) programs, the Medicare Shared Savings Program (MSSP) and the Next Generation ACO (NGACO) model, have been released. The results of the 2020 performance year for MSSP ACOs were overwhelmingly positive, despite having a difficult year in 2020 due to the COVID-19 pandemic. However, despite gross savings and a generally positive year, the short-lived NGACO model ultimately increased Medicare spending during its four-year program. This Health Capital Topics article will examine the key highlights of the 2020 MSSP and NGACO model performance results. (Read more...) 

This third installment of the internal medicine series will discuss the regulatory environment of the provision of internal medicine services. Healthcare providers face a range of federal and state legal and regulatory constraints, which affect their formation, operation, procedural coding and billing, and transactions. Fraud and abuse laws, specifically those related to the federal Anti-Kickback Statute (AKS) and physician self-referral laws (the “Stark Law”), may have the greatest impact on the operations of healthcare providers. It is crucial to understand these laws because violating them can result in criminal penalties, civil fines, and/or exclusion from federal healthcare programs. (Read more...) 
"Update on 2022 Healthcare Payment Rules" authored by HCC President, Todd A. Zigrang, MBA, MHA, FACHE, CVA, ASA, and, HCC Vice President and General Counsel, Jessica Bailey-Wheaton, Esq., was published by the National Association of Certified Valuators and Analysts (NACVA) in a recent issue of QuickRead.

For more recently published material written by HCC, please visit www.healthcapital.com

This one-hour webinar provides legal and valuation perspectives on the finalized changes to the Stark Law and the Anti-Kickback Statute. Specific issues covered include:

  • The changes to the “big three” requirements – Fair Market Value, Commercial Reasonableness, and the Volume or Value Standard;
  • The new exceptions and safe harbors for value-based arrangements, including where the Stark Law and Anti-Kickback Statute final rules differ; and
  • Other new and modified exceptions and safe harbors included in the final rules.