GreisGuide to LTACHs » hospital

HHS Puts Industry on Notice: OCR is Serious About HIPAA Enforcement

Jason Greis — Thu, 03 Mar 2011 04:22:21 +0000

On Feb. 22, 2011, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced that it had issued a civil money penalty (CMP) of $4.3 million against Cignet Health of Prince George’s County, MD., the first imposition of a CMP by OCR for a violation of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule. Two days later, HHS announced that General Hospital Corporation and Massachusetts General Physicians Organization, Inc., collectively referred to as Mass General, agreed to pay $1 million to settle potential violations of the HIPAA Privacy Rule. Read More...

Health Reform: Is the Hospital Industry Misapplying Congressional Intent?

Jason Greis — Thu, 14 Oct 2010 03:15:21 +0000

Thunder rolled down from Capitol Hill last week when Sen. Charles Grassley (R–Iowa) claimed that certain hospital systems and associations were misapplying the intent of Section 501(r)(5)(B) that prohibits the use of gross charges under the Patient Protection and Affordable Care Act. In their comments to the IRS regarding implementing regulations, the American Hospital Association (AHA) urged the IRS to apply a “gross charges” basis to charge those who do not qualify for financial assistance, and to use it as a starting place for calculating assistance to those who do. Read More...

ACOs and the Shared Savings Program: Some Common Misconceptions

Jason Greis — Sat, 02 Oct 2010 17:37:41 +0000

Section 3022 of the Patient Protection and Accountable Care Act (the Act) creates the Shared Savings Program for Medicare. Under the Shared Savings Program, which is to take effect no later than Jan. 1, 2012, Accountable Care Organizations (ACOs) that meet certain requirements established by the Secretary of Health and Human Services will be eligible to receive additional payments from Medicare where certain performance guidelines are met and cost-savings targets are achieved. The amount of the additional payment will be a percentage of the difference between the estimated per capita Medicare expenditures for patients assigned to the ACO and the cost-savings per capita Medicare expenditures threshold. Read More...

Complimentary McGuireWoods Webinar: The Impact of Healthcare Reform on Hospital Consolidation

Jason Greis — Wed, 25 Aug 2010 01:11:30 +0000

[ September 16, 2010; 12:00 pm to 1:00 pm. ] Thursday, September 16, 2010 Noon - 1 p.m. (ET) | 11 a.m. - Noon (CT) | 9 a.m. - 10 a.m. (PT) Complimentary Webinar Please join McGuireWoods and Juniper Advisory for an interactive webinar that will examine the impact of healthcare reform on hospital consolidation. The panel of speakers will address how the hospital community may react to [...]

Strategies for Hospital Leadership – Identifying Strengths, Allocating Hospital Resources and Focusing on Profitable Niche Leadership

Jason Greis — Mon, 16 Aug 2010 23:16:02 +0000

There are several different frameworks that can be used to build a strategy. Hospitals need to assess their overall strategy. One concept as to strategic approach proclaims that an organization should make a clear choice as to (1) whether an organization wants to be a low cost leader, (2) whether it wants to be dominant in a specific niche or area, or (3) whether it wants to be a leader in being customer centric. Michael Porter, noted author of Competitive Strategy, uses a similar framework and groups strategies into three generic strategies (i.e., strategies that are applicable across industries): cost leadership, differentiation, and focus. Porter argued that to be successful over the long term, a firm must select only one of these strategies. Otherwise, a firm will be “stuck in the middle” and will not achieve a competitive advantage.

2011 Medicare Payment Update for Post-Acute Care Providers

Jason Greis — Wed, 04 Aug 2010 03:44:05 +0000

The Centers for Medicare & Medicaid Services (“CMS”) has recently released various notices and final rules updating 2011 Medicare payment rates for post-acute care providers, including long-term acute care hospitals (“LTACHs”), inpatient rehabilitation facilities (“IRFs”), skilled nursing facilities (“SNFs”), home health agencies (“HHAs”) and hospices. These Medicare rate updates generally implement negative payment adjustments mandated by the Patient Protection and Affordable Care Act (Pub. L. No. 111-148), as amended by the Health Care and Education Reconciliation Act of 2010 (Pub. L. No. 111-152) (together, “PPACA”). Yet in spite of these adjustments, SNFs, hospices, IRFs and LTACH have fared relatively well with collective Medicare payment increases totaling $919 million, with HHAs offsetting these reimbursement gains by suffering a proposed $900 million Medicare reimbursement cut for calendar year 2011. Read More...

Patient Protection and Affordable Care Act – Provisions Impacting Institutional Providers

Jason Greis — Fri, 30 Apr 2010 18:43:30 +0000

The below CMS e-mail alert was distributed via grouplist on Thursday, April 22, 2010 and impacts LTACHs, among other institutional providers. Read More...

Eleven Things to Know about the False Claims Act

Jason Greis — Mon, 29 Mar 2010 22:44:27 +0000

In today’s era of increased fraud and abuse enforcement, it’s imperative that all individuals working in any facet of the healthcare industry be familiar with the basics of the False Claims Act and its recent evolution into a powerful regulatory tool for the government and private citizens. The McGuireWoods white paper “Eleven Things to Know About the False Claims Act” is a useful primer to help individuals identify potential violations of the False Claims Act. It will also help individuals better understand how the Act is enforced against and applied within the healthcare industry, including individual providers, medical device manufacturers and pharmaceutical companies. Read More...

Illinois Not-for-Profit Property Tax Exemptions, Charity Care and the Provena Decision

Jason Greis — Wed, 24 Mar 2010 02:49:39 +0000

Late last week the Illinois Supreme Court (the Court) issued its long-anticipated decision in the case of Provena Covenant Medical Center v. Illinois Department of Revenue (Provena). The Court’s opinion, delivered by Justice Karmeier, upheld the Illinois Department of Revenue (Revenue) Director Brian Hamer’s ruling that Provena Covenant Medical Center, located in Urbana, Ill. (PCMC), did not provide enough charity care services to justify the continuation of its charitable purpose property tax exemption. The Court’s opinion noted that PCMC’s parent company, Provena Hospitals, was the true property owner of PCMC, and that Provena Hospitals itself was not a charitable institution nor did it primarily serve charitable purposes. Furthermore, the Court held that PCMC provided only minimal levels of charity care thus the property was not being primarily used for charitable purposes. The Court’s decision will be problematic for not-for-profit hospitals, including LTACHs, because it leaves a key question unanswered—just how much charity must a hospital provide to justify an exemption? The decision is expected to encourage local taxing bodies to pursue efforts to remove tax exemptions of not-for-profit hospitals and other providers. Read More...

McGuireWoods 8th Annual Business & Legal Issues in Dialysis & Nephrology Symposium

Jason Greis — Tue, 23 Feb 2010 05:22:44 +0000

[ May 12, 2010; 7:30 am to 5:30 pm. ] Wednesday, May 12, 2010 7:30 a.m. - 5:30 p.m. Westin Chicago O'Hare 6100 River Road Rosemont, Illinois 60018 Click here to reach the online registration form Save the date for an engaging full-day seminar covering business and legal issues in dialysis and nephrology. Geared toward nephrologists; hospital and dialysis facility CEOs, CFOs and COOs; lawyers; administrators; and consultants, the symposium will [...]