Health Law Observer

Timely insights and legal commentary on various health care issues and developments surrounding regulations, employment, transactions and a range of key industry matters. This blog is maintained by the Health Care Department of Stevens & Lee.

FTC Policy Change May Signal Increased Scrutiny for “Anticompetitive” Healthcare Transactions

CMS Issues Final Rule Implementing Section 603 of the Bipartisan Budget Act of 2015

CMS issued the long-awaited Final Rule implementing Section 603 of the Bipartisan Budget Act of 2015 relating to payment for certain items and services furnished by off-campus provider-based departments of hospitals.
Tax Exempt Status

IRS Denies ACO Tax-Exempt Status

In denying Section 501(c)(3) tax-exempt status to an accountable care organization (ACO) formed by a Section 501(c)(3) health system, the IRS focused on four facts.
Payment Rates

Final Rule on Reporting and Returning Overpayments – the “60 Day Rule”

CMS stated that the Final Rule provides needed clarity and consistency for providers and suppliers on the actions they need to take to comply with requirements for reporting and returning of self-identified overpayments.
stethoscope laying on a book

CMS Updates Place of Service Codes for Professional Claims

Each of the new POS codes will be effective January 1, 2016, and neither of the new codes will have any effect on reimbursement.
Piggy Bank wiht Money and Computer

Change in CMP Law Affecting Gainsharing Arrangements

The change could clear the way for hospitals and physicians to share payments for reducing or limiting medically unnecessary services provided to Medicare and Medicaid beneficiaries.

Practical Guidance for Health Care Governing Boards on Compliance Oversight

An educational resource designed to assist governing boards of health care organizations to carry out their compliance oversight obligations was published on April 20, 2015.
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