By Kim Stanger and Allison (Ally) Kjellander
HHS has issued helpful FAQs that answer common questions concerning the No Surprise Billing Rules and self-pay patients, available here. The FAQs confirm the following: Read more
By Kim Stanger
HHS has updated the Terms and Conditions and websites for two key portions of its Provider Relief Fund programs.
1. Provider Relief Funds. Over the weekend, HHS updated the Terms and Conditions and posted FAQs concerning the Provider Relief Fund, available here: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html. The new Terms and Conditions apply to the $50 billion General Distribution funds that have gone out and will go out over the next few weeks, and reaffirm reporting requirements as well as potential fraud and abuse liability for failing to comply. See https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/terms-conditions/index.html. HHS also opened the portal for those entities entitled to apply for additional General Distribution funds. https://covid19.linkhealth.com/docusign/#/step/1. The FAQs provide detailed information concerning eligibility, requirements, and information necessary to apply for additional funds. https://www.hhs.gov/sites/default/files/20200425-general-distribution-portal-faqs.pdf. Significantly, those who received the a portion of the $20 billion disbursement last week must still provide information confirming their patient revenues as well as attest to the updated Terms and Conditions relevant to that program. Read more
By Karina Sargsian and Kim Stanger
The CARES Act adopts several measures to help stabilize the healthcare system, address health care issues directly and indirectly related to the current pandemic and ensure future preparedness. It also allocates $100 billion of direct funding to help hospitals keep their doors open. Many of the provisions are only tangentially related to the current pandemic, such as re-appropriations for a variety of health programs. Read more
By Little V. West, Kaitlyn Luck, and Lisa Carlson
On November 15, 2019, CMS issued a final rule pursuant to President Trump’s June 24, 2019, Executive Order to ensure price transparency by healthcare facilities. This price transparency rule will go into effect January 1, 2021, and will require hospitals operating within the United States to establish, update, and publicize all standard charges for all items and services provided by the hospital. Hospitals will also be required to display, in a consumer-friendly manner, standard charges for at least 300 shoppable services provided by the hospital. The stated purpose of this rule is to “increase market competition, and ultimately drive down the cost of healthcare services, making them more affordable for all patients.”
by Kim Stanger
The Idaho Department of Health and Welfare has implemented new patient rights rules for hospitals effective July 1, 2019. (See IDAPA 16.03.14.220 to .350). The rules were advanced by patient advocacy groups and, to a large degree, incorporate standards that parallel—but do not exactly mirror—existing law and/or Medicare conditions of participation for hospitals. Because many of those regulatory conditions did not apply to critical access hospitals (“CAHs”), CAHs may need to implement new policies and procedures to satisfy the rules. All Idaho hospitals as well as providers rendering services in hospitals should check their existing policies and practices against the new rules, including the following:
Read moreThis publication is designed to provide general information on pertinent legal topics. The statements made are provided for educational purposes only. They do not constitute legal or financial advice nor do they necessarily reflect the views of Holland & Hart LLP or any of its attorneys other than the author. This publication is not intended to create an attorney-client relationship between you and Holland & Hart LLP. Substantive changes in the law subsequent to the date of this publication might affect the analysis or commentary. Similarly, the analysis may differ depending on the jurisdiction or circumstances. If you have specific questions as to the application of the law to your activities, you should seek the advice of your legal counsel.
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