By Seth Carver, Class of 2020; Andrew F. Solinger, Associate at Waller With the start of hurricane season, and the recent destruction caused by Hurricane Florence on the Carolinas and beyond, hospitals must review and update their policies and procedures to ensure that proper care can be provided to patients following surges caused by natural …
Federal government tightening enforcement for hospice, post-acute care providers
By Curtis Campbell, Class of 2019; Jessie C. Neil, Partner at Waller; J. Logan Wilson, Associate at Waller The Department of Health and Human Services’ Office of Inspector General (OIG) recently announced that it had found several vulnerabilities in the Medicare hospice program while examining practices between 2006 and 2016. The number of beneficiaries in the program …
Pathways to Success: CMS proposes accelerated shift to provider risk in ACOs
By Clay Brewer, Class of 2020; Jesse C. Neil, Partner at Waller In an effort to facilitate the American healthcare system’s transformation from volume-based to value-based payment, the Centers for Medicare and Medicaid Services (CMS) is requesting public comment regarding its newly proposed rule that would shift the amount of risk participants in Accountable Care …
10 ways you can protect your company from a cyberattack
By Emmie Futrell, Class of 2018; Robb S. Harvey, Partner at Waller; Elizabeth N. Pitman, Counsel at Waller The government, through the United States Department of Justice, has increased its efforts to respond to cyberattacks, a hot-button issue that extended across disciplines in 2017. The newly created Cyber-Digital Task Force has been charged with developing policies to combat global …
Why telehealth was a big winner in new budget deal
By Andy Cole, Class of 2018; Amber Greene Arnold, Associate at Waller Hidden in the details of the Bipartisan Budget Act of 2018 are some key telehealth provisions that are receiving praise from many industry groups and could mark a significant development for Medicare telehealth policy. The new legislation promotes telehealth in several ways. Tele-stroke. Medicare …
Between a rock and a hard place: medical-device stakeholders disappointed by cancelled CMS rulemaking
By Emmie Futrell, Class of 2018; Denise D. Burke, Partner at Waller Another attempt at bridging the gaping lag between FDA approval for medical devices and CMS’s Medicare coverage determinations has been struck down, after a nine-month standstill. CMS’s proposed rulemaking included a promising new program called EXCITE, or expedited coverage of innovative technology. The proposed …
Volume I Released
We are excited to announce the release of Volume I of The Practitioner’s Guide to Health Care Law and Policy. Volume I consists of the transcripts from the 2017 Symposium and notes by Chase Doscher and Zachary Gureasko. Volume I can be found online here.
CMS unveils new bundled payment model
By Chase Doscher, Class of 2018; Elizabeth N. Pitman, Counsel at Waller; Zachary D. Trotter, Associate at Waller Earlier this month, CMS announced the launch of the Bundled Payment for Care Improvement Advanced (BPCI Advanced) payment model. This is the first Advanced Alternative Payment Model (Advanced APM) introduced under the Trump Administration and the start of the …
Back to the Future: CMS revives Obama-era proposed rule on critical access hospitals
By Emmie Futrell, Class of 2018; Kristen A. Larremore, Partner at Waller; Amber Green Arnold, Associate at Waller Since the 1997 Balanced Budget Act, which created the designation for Critical Access Hospitals (CAH), the requirements for Medicare and Medicaid participation for these rural facilities have largely remained untouched. But, a recent decision by CMS to revive and …
OIG Gives Green Light to Gainsharing Arrangement
By Brandon Huber, Class of 2019; Kim Harvey Looney, Partner at Waller; Justin Hickerson, Associate at Waller A gainsharing arrangement between a non-profit hospital and members of a multi-specialty physician group has been authorized by the Office of Inspector General for the first time since the 2015 enactment of MACRA removed certain roadblocks from the expanded use …