CMS Issues Stark Act Voluntary Self-Referral Disclosure Protocol – 9 Key Concepts

Posted by Jason Greis on October 17, 2010 under Articles | Be the First to Comment

The Patient Protection and Affordable Care Act (PPACA) requires the Secretary of the Department of Health and Human Services (HHS), with the Office of the Inspector General (OIG) of HHS, to establish a protocol for healthcare providers and suppliers to disclose actual or potential violations of Section 1877 of the Social Security Act (Stark Act). Under the Stark Act, healthcare providers and suppliers may not refer patients to any entity for certain services if the physician has a financial relationship with that entity, unless an exception for such referral applies. Read More...

Health Reform: Is the Hospital Industry Misapplying Congressional Intent?

Posted by Jason Greis on October 13, 2010 under Articles | Be the First to Comment

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

Posted by Jason Greis on October 2, 2010 under Articles | Be the First to Comment

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

Posted by Jason Greis on August 24, 2010 under Events | Be the First to Comment

Thursday, September 16, 2010
Noon – 1 p.m. (ET) | 11 a.m. – Noon (CT) | 9 a.m. – 10 a.m. (PT)
Complimentary Webinar
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Strategies for Hospital Leadership – Identifying Strengths, Allocating Hospital Resources and Focusing on Profitable Niche Leadership

Posted by Jason Greis on August 16, 2010 under Whitepapers | Be the First to Comment

This is a great time for hospital leadership and boards to reevaluate their strategies.   The attached whitepaper written by two of my colleagues, Scott Becker and Bart Walker, contains eight core thoughts and concepts on strategic planning for hospitals. Read More...

CMS Issues Proposed Rule on Changes to Stark In-Office Ancillary Services Exception

Posted by Jason Greis on August 12, 2010 under Articles | Be the First to Comment

Section 6003 of the Patient Protection and Affordable Care Act, Public Law 111-148 (H.R. 3590) (PPACA) makes a change to the “in-office ancillary services” exception to the Stark physician self-referral law that impacts physician practices providing certain radiology services in their offices. In short, the change requires physicians making a referral for magnetic resonance imaging (MRI), positron emission tomography (PET), and computed tomography (CT), or certain other radiology services in their offices, to make a disclosure to the patient that such services can be provided elsewhere and to include a list of alternative providers. Read More...