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CMS Issues MACRA Proposed Rule One Year After Passage 
On May 9, 2016, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for implementing changes to the value-based reimbursement (VBR) scheme required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The proposed rule introduces the Quality Payment Program (QPP), which implements the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs), both of which were first set out in MACRA. The effects of this initiative are expected to be widespread, as by 2020, the QPP may affect up to 800,000 clinicians. This Health Capital Topics article will briefly discuss the background of MACRA, and detail the requirements and the potential consequences regarding MIPS and APMs.

On May 9, 2016, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for implementing changes to the value-based reimbursement (VBR) scheme required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The proposed rule introduces the Quality Payment Program (QPP), which implements the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs), both of which were first set out in MACRA. The effects of this initiative are expected to be widespread, as by 2020, the QPP may affect up to 800,000 clinicians. This Health Capital Topics article will briefly discuss the background of MACRA, and detail the requirements and the potential consequences regarding MIPS and APMs.  (Read more...) 

On April 8, 2016, the Internal Revenue Service (IRS) publicly released its Private Ruling 201615022, dated January 15, 2016, which denied granting tax-exempt status under Section 501(c)(3) of the Internal Revenue Code (IRC) to an accountable care organization (ACO) not participating in the Medicare Shared Savings Program (MSSP). The IRS found that a substantial portion of the activities of the ACO, in particular negotiating agreements with third-party payors on behalf of member physicians, benefited private individuals to such a degree that the IRS deemed the ACO to have a "substantial nonexempt purpose [that] destroys the exemption under 501(c)(3)." The ruling  provides a further example of regulatory scrutiny related to tax-exempt status of healthcare enterprises, in conjunction with recent tax rulings in New Jersey and Illinois. This Health Capital Topics article, the second and final installment of the two-part series examining the increasing regulatory scrutiny regarding the tax-exempt status of healthcare enterprises, will detail this IRS ruling, as well as how the ruling continues the recent regulatory trend scrutinizing tax-exempt status and the potential implications of this trend for health systems.  (Read more...) 

Over the past few years, there has been increasing interest and research in electroceuticals, which are devices that target individual nerve fibers or specific brain circuits to treat an array of medical conditions. The devices modulate the neural impulses that control many voluntary and involuntary movements of the human body, repair lost function, and reinstate a healthy balance. Electroceuticals may treat major conditions such as hypertension, diabetes, obesity, heart failure, pulmonary disorders, and vascular disease. Not only could these devices treat major conditions, but they could do so in a safe, non-intrusive manner. Currently, many electroceutical devices, such as pacemakers, defibrillators, and deep-brain stimulators, exist on the market which harness electrical impulses to treat various diseases. However, currently available electroceutical devices do not target specific cells and are limited in their scope for expansion. This Health Capital Topics article will discuss the increasing interest in the electroceuticals industry and the potential impact that electroceuticals may have on healthcare delivery.  (Read more...)

On February 2, 2016, the Centers for Medicare and Medicaid Services (CMS) announced that the agency is extending the temporary moratorium on certifying Medicare home health agencies (HHA) and Medicare Part B ground ambulance suppliers in select metropolitan areas across the U.S., until July 29, 2016. The moratorium targets certain counties, viewed by CMS as areas with high rates of healthcare fraud and abuse, in six (6) states: Florida, Illinois, Michigan, Texas, Pennsylvania, and New Jersey. Since CMS initially instituted the moratorium on July 30, 2013, for select counties in Florida, Texas, and Illinois, CMS has further extended and broadened the moratorium to include additional counties and states on five different instances: January 30, 2014, August 1, 2014, February 2, 2015, July 28, 2015, and January 29, 2016. This moratorium reflects the continued scrutiny of healthcare fraud and abuse by government regulators, which may influence the operations of healthcare providers. This Health Capital Topics article will detail the history of CMS's utilization of the moratorium on provider certification, and how this regulatory tool reflects the overall trend of continued scrutiny related to healthcare fraud and abuse.  (Read more...)