Bundled Payment Hiatus….or, Demise?

Within the last few days, CMS/HHS sent a proposed rule to OMB (Office of Management and Budget) that would cancel the planned January 2018 roll-out of the (mandatory) cardiac and traumatic joint repair/replacement bundles.  Specifically, CMS was adding bypass and myocardial infarction DRGs to the BPCI (Bundled Payments for Care Improvement) along with DRGs pertaining to … Read more

SNF M&A: The Provider Number Trap

Over my career, I have done a fair amount of M&A work….CCRCs, SNFs, HHAs, Physician practices, hospice, etc. While each “deal” has lots of nuances, issues, etc. none can be as confusing or as tricky to navigate as the federal payer issues; specifically, the provider number.  For SNFs, HHAs, and hospices, an acquisition not properly … Read more

CMS Issues Proposed Home Health Rule for 2015

Just ahead of the Fourth of July holiday, CMS released its proposed home health rule changes for FY 2015.  As common, the proposal includes rate changes/modifications and clarifications and adjustments to Conditions of Participation.  The proposed rule continues a path for CMS and the industry of rate reduction/rate rebasing and movement toward greater emphasis on … Read more

Obamacare/ACA: Implications for Consumers

Having jumped around just a bit in the last few weeks “topically”, this post may seem a bit disjointed.  It is meant as a continuation of a series I’ve compiled on the various implications providers, consumers, etc. can/will experience under the Affordable Care Act (a/k/a Obamacare).  Given the news cycle of late and the recent roll-out of … Read more

Obamacare/ACA: Implications for Providers

This is the second post of a four-part series on the status and implications of the continuing roll-forward/roll-out of the Affordable Care Act (aka Obamacare).  In this post, the context is the implications for providers, given the evolving state of the ACA and some of the current uncertainty of its future. Important to note: Affirmatively, the … Read more

False Claims Act: Providers Beware

Lately I have fielded a growing number of questions regarding various applications/uses of the False Claims Act and Medicare billing inquiries.  What is disconcerting about these inquiries is their source; too many from providers or provider organizations.  One in particular arises out of an acquisition and this bears special note and comment which, I have … Read more

What’s Trending: Catching Up

Probably the biggest trend as of late is my tardiness in getting these posts out on-time…sorry.  My end of the week (last week) got distorted as I needed to attend a meeting with regard to a Medicaid shift in Kansas from fee-for-service to “managed”.   As I have been through these conversions or switches before, it’s … Read more

Financial Tests Before Additions, Renovations or New Construction

A frequent, recurring question that I field, especially for CCRCs and seniors housing providers is “what” financial feasibility tests are most important before a project is started or for that matter, financed.  Given that capital is still relatively tight, project feasibility and key financial tests are today, critically important to assure the best financing terms available … Read more

Medicare SNF Rate Outlook

Literally fresh off of a significant rate adjustment/reduction in October (2011), Medpac (the Medicare Payment Advisory Commission) releases a recommendation for complete SNF payment overhaul.  In their assessment of the SNF payment system under Medicare, Medpac concludes the following; Medicare payments to SNFs represent 23% of all revenues.  Medicare (payer) as a share of SNF patient … Read more