Responding to Non-Network Plans Using Reference-Based Pricing

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An increasing number of employer-sponsored health plans are electing not to enter into contractual agreements with hospitals through an established provider network. These plans seek to limit payment for hospital services provided to plan beneficiaries by repricing the services at a plan-determined amount, typically based upon a percentage of Medicare reimbursement,... Continue Reading →

Twenty-One States File Lawsuit Challenging New Wage and Hour Overtime Rules

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On May 17, 2016, the U.S. Department of Labor (“DOL”) announced the details of its final rule under the Fair Labor Standards Act, establishing new salary thresholds for millions of traditionally exempt white collar employees effective December 1, 2016. These changes would significantly impact many employers’ budgets in the coming months.  The main... Continue Reading →

Hall Render’s This Week in Washington – September 16, 2016

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House, Senate Chairman Highlight GAO Report on Medicaid Reform Late last week, House Energy and Commerce Committee Chairman Fred Upton (R-MI) and Senate Finance Committee Chairman Orrin Hatch (R-UT) highlighted a new GAO report on Medicaid reform. The report was released by the non-partisan Government Accountability Office (“GAO”) detailing policy considerations... Continue Reading →

Questions Surround CMS’s Announcement of Participation Options for MIPS and Advanced APMs for 2017

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As has been widely reported, CMS’s Acting Administrator, Andy Slavitt, recently announced four participation options under the Quality Payment Program (i.e., participation in the MIPS and Advanced APM programs) for 2017. In part because the September 8 announcement provides only summary descriptions, many questions surround the four participation options and... Continue Reading →

The Joint Commission Revises Statement of Conditions Process

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Background Hospitals and other facilities that are accredited by The Joint Commission work to ensure compliance with The Joint Commission’s “Life Safety” chapter, which requires compliance with the National Fire Protection Association’s NFPA 101: Life Safety Code (“LSC”).  As part of those efforts, many accredited facilities have used The Joint Commission’s... Continue Reading →


Update: Michigan Senate Passes Bill to Expand Certified Nurse Anesthetist Scope of Practice

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On September 8, 2016, the Michigan Senate passed a bill on a 22-15 vote, which expands the scope of practice for certified nurse anesthetists (“NAs”). Senate Bill 1019 amends Sections 17210 and 17708 of the Michigan Public Health Code (the “Code”). Specifically, the bill adds certain anesthesia and analgesia services to... Continue Reading →

Joint Ventures Between Health Care Providers and REITs: Five Things to Consider

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Hospitals are increasingly becoming targets for investment by real estate investment trusts (“REITs”), with the past year seeing a number of high profile joint ventures between REITs and health care providers structured as RIDEA investments. While hospital/REIT joint ventures can help hospitals fund expansions or monetize valuable real estate assets,... Continue Reading →