February 20, 2020

Retroactive Repeal of Parking Taxes: A Win for the Nonprofit Sector

Under the Tax Cuts and Jobs Act, certain expenditures related to providing employee parking were deemed unrelated business taxable income and resulted in taxable income for nonprofit organizations. This provision was highly unpopular in the tax-exempt sector. It resulted in a tax burden for organizations that typically did not owe income taxes, and an increase in administrative burden, due to complicated and tedious calculations.

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Topics: TCJA

January 23, 2020

Recent CMS Rulings Simplify Payments for Transitional Care Management

In recent years, the use of care management services to provide better patient outcomes has gained momentum. Contributing to this momentum is a desire to generate greater transparency around patient behaviors in Post-Acute Care settings. This setting was the first focus area for the creation of care management services.

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Topics: Physician Compensation, Patient Care, Managed Care Organization, CMS

December 05, 2019

What the Transparency in Coverage Proposed Rule Could Mean for the Healthcare Marketplace

The Department of Health and Human Services recently released the Transparency in Coverage proposed rule. It is a response to President Trump’s executive order to “Improve Pricing and Quality Transparency in American Healthcare.” It comes with significant implications for insurers, providers, consumers, and government agencies. The purpose behind it is to lower healthcare spending and increase quality by creating real-time, user-friendly data on pricing and healthcare service rates.

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Topics: Transparency, healthcare

November 21, 2019

Recent Legislative Impacts to Telemedicine in Care Delivery

Legislative support is growing for the reimbursement of care delivery via telemedicine. The Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) have recently made final and proposed rule changes to stimulate greater use and access for telemedicine delivery. These changes mean that for healthcare providers all around the United States, telemedicine will become a greater strategic focus.

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Topics: Telecommunications

November 14, 2019

2020 Medicare Physician Fee Schedule Final Rule Highlights

A final rule updating the physician fee schedule rates was issued by The Centers for Medicare and Medicaid Services (CMS) this month. The new regulation, which increases the 2019 conversion factor of $36.04 to $36.09 in 2020, will be published in the Federal Register on November 15, 2019.

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Topics: Medicare, Physician Compensation

October 31, 2019

Valuation of Specialty Pharmacies

The specialty pharmacy marketplace in the US has experienced rapid growth in recent years. The number of specialty pharmacies operating in the US has more than doubled since 2015. US expenditures for specialty drugs have also nearly doubled from $83 billion in 2013 to $157 billion in 2017. Combined with spending on orphan drugs, total US expenditures on specialty pharmaceuticals is now nearly equal the amount spent on traditional medications.[1],[2]

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Topics: Healthcare Valuation, Valuation

October 17, 2019

Proposed Changes to Stark Law Encourage Transition to a Value-Driven Healthcare System

Last week, the Department of Health and Human Services (HHS) and the Center for Medicare and Medicaid (CMS) revealed proposed changes to “modernize” and clarify regulations that interpret the Physician Self-Referral Regulations (Stark Law) and the Federal Anti-Kickback Statute. The Proposed Rule immediately highlights a focus on the transition to a value-driven healthcare system, which is in-line with the OIG’s priorities. 

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Topics: Value-Based Care, Stark Law

October 10, 2019

Is Your Physician Contract Commercially Reasonable?

When considering Stark Law exceptions for vetting financial arrangements with physicians, we often witness a tendency to focus primarily on Fair Market Value (FMV). This is rightly so, as ensuring physician contracts comply with FMV is a critical part of risk management.

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Topics: Physician Compensation, FMV, Commercially Reasonable

October 03, 2019

Selecting the Right Level of Appraisal or Valuation

For those seeking valuation or appraisal services, the varying levels of services offered can often be confusing to navigate. Appraisers/valuators offer many different services to meet the needs of a diverse client base. Confusion in the process of selection can lead clients to select a service based solely on price, only later to discover, as with many things in life, you get what you pay for. 

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Topics: FMV, Valuation

September 19, 2019

Fair Market Valuation of Accountable Care Organizations

An accountable care organization (“ACO”) is a healthcare delivery entity characterized by a payment model that facilitates coordination among providers — charged with the care of a specified patient population.

Participation in an ACO is voluntary, and participants must be willing to become accountable for the quality, cost, and overall care of the specified population. Commonly, ACOs receive capitated payments based on the size of the patient population served, though other reimbursement models exist. ACO participants are financially incentivized to lower healthcare costs while improving quality as they share in a portion of the excess between total capitated payments and total healthcare costs.

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Topics: Fair Market Value, FMV, ACO

August 29, 2019

6 Questions to Ask When Assessing a Physician On-Call Arrangement

On-call pay is the hospital’s payment for access to physicians providing call coverage. The provision of on-call pay to physicians continues to be a hot topic for hospital leaders and physicians. Therefore, it is important from a strategic, financial and regulatory perspective to properly structure physician on-call pay arrangements.

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Topics: Physician Compensation

August 15, 2019

Fair Market Value Physician Compensation Fails

Determining fair market value (FMV) compensation in a healthcare setting generally requires the use of multiple, objective data points and an understanding of how to apply that information given the unique facts and circumstances of the subject arrangement relative to the overall market.

Understanding what the government considers as support for FMV, and what it does not, is critical to selecting and enacting policies and procedures for establishing FMV physician compensation.

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Topics: Physician Compensation, Fair Market Value

August 08, 2019

IPPS Final Rule FY 2020 — 3 Main Takeaways

There are two things I know will happen at the beginning of August: Football is about to begin and the newest updates on the next fiscal year payment system will soon be released. Last Friday, the Federal Fiscal Year (FFY) 2020 Inpatient Prospective Payment System (IPPS) Final Rule was released. This quickly changed my weekend plans as I delved into the details to fully understand what changes the Centers for Medicare and Medicaid Services (CMS) would implement for FFY 2020. I’m just glad it was before football season started.

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Topics: IPPS

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