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Transforming Primary Care: CMS Launches Making Care Primary (MCP) Model
August 8, 2023 | Blog | By Rachel Yount, David Gilboa, Stephnie John
The Centers for Medicare & Medicaid Services (CMS) announced a new primary care model—the Making Care Primary (MCP) Model—geared towards smaller, independent primary care practices and organizations that want to participate independently in value-based care initiatives. The MCP Model will be tested in eight states - Colorado, Massachusetts, Minnesota, New Mexico, New Jersey, New York, North Carolina, and Washington.
CMS Announces GUIDE – a New Dementia Care Model Designed for Participation by a Range of Providers
August 2, 2023 | Blog | By Rachel Yount
Health care providers furnishing dementia care should take note of a new payment model announced by the Centers for Medicare & Medicaid Services on July 31, 2023, called Guiding an Improved Dementia Experience (GUIDE). GUIDE is designed to improve dementia care, reduce strain on unpaid caregivers, and help people with dementia remain in their homes and communities. Providers participating in GUIDE receive monthly per-beneficiary per-month payments, can bill for respite care services, and are eligible for one-time payments to support infrastructure.
New Group Practice Information Form for the Stark Law’s Self-Referral Disclosure Protocol
February 2, 2023 | Blog | By Rachel Yount
The Stark Law’s Self-Referral Disclosure Protocol (SRDP) will include a new Group Practice Information Form for physician practices to report any noncompliance arising from not fully satisfying the Stark Law’s definition for a “group practice,” effective March 1, 2023. The Centers for Medicare & Medicaid Services (CMS) intends for the changes to reduce regulatory burden and streamline the disclosure process.
CMS Issues Additional Flexibilities to the ACO REACH Model’s Benefit Enhancements
December 16, 2022 | Blog | By Rachel Yount
As Accountable Care Organizations (ACOs) and providers gear up for the start of the new ACO REACH Model in 2023, CMS recently issued helpful policy updates to the model’s benefit enhancements (BEs). Under BEs, CMS waives certain Medicare payment requirements for services provided to REACH beneficiaries through the REACH ACO’s participant providers and preferred providers. REACH ACOs can opt to use one or more of the BEs, which are designed to create flexibility in managing REACH beneficiaries’ care. REACH ACOs have full control over which providers participate in any BE. As discussed below, CMS recently announced updates to two of the model’s BEs – the 3-Day Skilled Nursing Facility (SNF) Rule Waiver and the Nurse Practitioner (NP) Services.
CMS Announces Changes to the MSSP Designed to Increase MSSP Participation and Promote Equity within the MSSP
November 17, 2022 | Blog | By Rachel Yount
The Centers for Medicare & Medicaid Services (CMS) recently announced changes to the Medicare Shared Savings Program (MSSP) designed to improve equity within the MSSP and increase the percentage of Medicare beneficiaries in accountable care arrangements. The changes are included in the Calendar Year 2023 Physician Fee Schedule final rule (Final Rule), which is scheduled for publication on November 18, 2022.
Combatting Patient Leakage by Directing Physician Referrals: What is Permitted under the Stark Law?
July 29, 2021 | Blog | By Karen Lovitch, Rachel Yount
To the contrary, the Stark Law actually permits directed referral requirements, provided that certain conditions are met. CMS recently enacted changes to the Stark Law regulations, effective January 19, 2021, that provide additional clarity on how health care providers can permissibly use directed referral requirements. These recent changes have seemingly triggered new awareness and interest in how health care systems can utilize directed referral requirements to combat patient leakage.
HHS Finalizes Highly Anticipated Final Rule Amending Anti-Kickback Statute and Stark Law Regulations, Part VI: Changes to Fundamental Stark Law Terminology
February 8, 2021 | Blog | By Karen Lovitch, Rachel Yount
HHS Finalizes Highly Anticipated Final Rule Amending Anti-Kickback Statute and Stark Law Regulations, Part V: Cybersecurity Technology and Electronic Health Records
February 4, 2021 | Blog | By Karen Lovitch, Rachel Yount
In this fifth installment of our blog series covering the changes, we dive into (i) the new AKS safe harbor and Stark Law exception for cybersecurity technology and related services, and (ii) the significant changes to the existing safe harbor and exception for electronic health records (EHR) technology.
HHS Finalizes Highly Anticipated Final Rules Amending AKS and Stark Law Regulations, Part IV: Changes to Existing Safe Harbors and Stark Law Exceptions
December 11, 2020 | Blog | By Karen Lovitch, Bridgette Keller, Rachel Yount
HHS Finalizes Highly Anticipated Final Rules Amending AKS and Stark Law Regulations, Part III: Value-Based Arrangements
December 7, 2020 | Blog | By Rachel Yount
Plus, we have prepared easy-to-read comparison charts breaking down the current, proposed, and final regulations. These comparison charts offer a quick way to get up to speed on these voluminous final rules and their many historic changes to the AKS and Stark Law.
HHS Finalizes Highly Anticipated Final Rules Amending Anti-Kickback Statute and Stark Law Regulations, Part II: Beneficiary Inducement
December 1, 2020 | Blog | By Karen Lovitch, Rachel Yount, Jane Haviland
HHS Finalizes Highly Anticipated Final Rules Amending Anti-Kickback Statute and Stark Law Regulations
November 23, 2020 | Blog | By Karen Lovitch, Rachel Yount
CMS Announces One-Year Delay in Finalizing Highly Anticipated Stark Law Reform
August 27, 2020 | Blog | By Karen Lovitch, Rachel Yount
HHS Proposes Sweeping Changes to AKS and Stark Law, Part 6: Proposed Changes to the AKS Related to Beneficiary Inducement
December 18, 2019 | Blog | By Karen Lovitch, Rachel Yount, Jane Haviland
HHS Proposes Sweeping Changes to AKS and Stark Law, Part 5: Proposed Changes to Key Stark Law Requirements and Numerous Stark Law Exceptions
November 21, 2019 | Blog | By Karen Lovitch, Rachel Yount
HHS Proposes Sweeping Changes to AKS and Stark Law, Part 4: Modifications to Key Stark Law Terminology and a New Stark Law Exception
November 13, 2019 | Blog | By Karen Lovitch, Rachel Yount
HHS Proposes Sweeping Changes to AKS and Stark Law, Part 3: Personal Services and Management Contracts, Outcomes-Based Payments, and Warranties
October 23, 2019 | Blog | By Karen Lovitch, Theresa Carnegie, Rachel Yount
HHS Proposes Sweeping Changes to AKS and Stark Law, Part 2: Cybersecurity Technology and Electronic Health Records
October 21, 2019 | Blog | By Karen Lovitch, Dianne Bourque, Theresa Carnegie, Rachel Yount
HHS Proposes Sweeping Changes to AKS and Stark Law, Part 1: Value-Based Arrangements
October 15, 2019 | Blog | By Theresa Carnegie, Rachel Yount
HHS Proposes Sweeping Changes to Anti-Kickback Statute and Stark Law
October 10, 2019 | Blog | By Karen Lovitch, Theresa Carnegie, Rachel Yount
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