Congress Changes Reimbursement Rules for Off-Campus Facilities
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015 (BBA). While the law contains a number of budgetary changes that impact broader economic issues, including the debt ceiling and the federal tax code, the law also prohibits off-campus hospital outpatient departments (HOPDs), also called provider-based departments, created after November 2, 2015, from collecting Medicare reimbursement for non-emergency services under the outpatient prospective payment system (OPPS) starting on January 1, 2017. This change in hospital outpatient billing may impact current and future planning by providers in regard to establishing off-campus HOPDs. This Health Capital Topics article will detail the provisions of the BBA related to hospital outpatient reimbursement and discuss the impact of the BBA on hospital outpatient facilities. (Read more...)

OIG Releases 2016 Work Plan
In November 2015, the Office of Inspector General (OIG) of the U.S. Department of Health & Human Services (HHS) published its 2016 Work Plan, which highlights the audits, evaluations, and initiatives that the OIG expects to conduct during 2016. The 2016 Work Plan adds new topic areas that the OIG previously had not examined, such as ICD-10 implementation, while also updating existing projects and expected report release dates for many relevant healthcare issues, such as claims auditing and the two-midnight rule. This Health Capital Topics article will highlight the key changes and continued focus areas for the OIG during 2016, as well as emphasize the prudence of organizations to look beyond the 2016 Work Plan in developing its compliance efforts, particularly in relation to the regulatory thresholds of fair market value and commercial reasonableness. (Read more...)

Updated Two-Midnight Rule Released
Over the last several years, improvements in technology and medical practices have allowed many formerly complex or dangerous procedures, which required patients to stay in a hospital, to be performed more simply or safely, thus drawing attention to the distinction between inpatient and outpatient services. In some cases, the difference between inpatient and outpatient services may seem arbitrary, due to the fact that the determining factor between inpatient care and outpatient care is whether or not a doctor admitted the patient to the hospital; a patient may stay in a hospital bed overnight but still be considered an outpatient. In August of 2013, the Centers for Medicare and Medicaid Services (CMS) issued a rule that sought to standardize the classification of Medicare beneficiaries as either inpatients or outpatients, known as the Two-Midnight Rule. In November of 2015, after years of criticism from industry providers, CMS published revisions to this rule. This Health Capital Topics article will explore the basis of the original Two-Midnight Rule, the circumstances leading to the revision of this rule, the recent revisions to the Two-Midnight Rule, and the potential impact on providers operating under this rule. (Read more...)

Medicare Releases Comprehensive Care for Joint Replacement Model
In November of 2015, CMS published a final rule detailing the Comprehensive Care for Joint Replacement (CJR) program. In brief, CJR is a bundled payment model that holds hospitals accountable for all of the care associated with hip and knee replacement surgeries, as opposed to only holding hospitals responsible for the cost and quality of the inpatient stay associated with these surgeries. In enacting this program, which is slated to begin on April 1, 2016, CMS is continuing its drive towards value-based care, by offering incentives for providers to reduce spending, and improve the quality and coordination of care for many Medicare beneficiaries. This Health Capital Topics article will detail the methodology behind the CJR model, as well as explore how the CJR program may impact participating providers. (Read more...)

HCC - 2015 - Our 23rd Year of Achievements!
An illustrative selection of HCC's client engagements and professional activities for the year 2015. (Read more...)