On September 28, 2018, the Iowa Department of Human Services issued an informational letter (Informational Letter No. 1953-MC-FFS-D) to all Federally Qualified Health Centers (“FQHCs”) that eliminated the productivity requirements that had previously applied to FQHCs in Iowa. The change is effective for cost reporting periods ending on or after […]
Health Law Alert
First Release of Quality Reporting Data (QRP) About Skilled Nursing Facilities on Nursing Home Compare
On October 24, 2018, CMS released “inaugural” QRP data on Nursing Home Compare regarding skilled nursing facilities (SNFs). This release is in accordance with Section 1899B(g)(1) of the Social Security Act requiring CMS to publicly report SNF provider performance on selected quality measures. Reporting of certain quality measures is also […]
New Fraud Risk Indicator on the OIG Website
On September 27, 2018, a new post on the OIG website www.oig.hhs.gov educates providers about the Fraud “Risk Spectrum” which categorizes risk from low to the high as follows: the highest risk is program exclusion, followed by the high risk of heightened scrutiny, the medium risk of imposition of a […]
Preventing Common 501(r) Mistakes
Section 501(r) of the Internal Revenue Code (“Code”) and the final regulations published by the IRS put into place very specific requirements for tax-exempt hospitals relative to financial assistance policies (FAPs) and community health needs assessments (CHNAs). The Code requires the IRS to perform desk reviews of the Form 990, […]
Deregulation Continues: CMS Proposes Reducing Medical History and Physical Examination (“H&P”) Requirements for ASCs and Acute-Care Hospitals
On September 20, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that would “reform Medicare regulations that are identified as unnecessary, obsolete, or excessively burdensome on health care providers and suppliers” (“Proposed Rule”). One of the more significant proposals would eliminate the current comprehensive medical […]