D.C. Appeals Court Upholds CMS's Authority to Limit Payment for Services
E&M services limited at off-site provider-based locations.
The U.S. Court of Appeals for the District of Columbia recently upheld CMS's authority to broaden site-neutral payment reductions for evaluation and management services furnished at longstanding off-campus provider-based locations. CMS's new policy was quite important given that E&M services is about 50 percent of all separately payable or conditionally packaged services provided by outpatient departments every year. This white paper reviews the background of the ruling and discusses the appellate court arguments and rulings.
Baker, Donelson, Bearman, Caldwell & Berkowitz, PC
Leslie Demaree Goldsmith is a shareholder at Baker, Donelson, Bearman, Caldwell & Berkowitz, PC. Ms. Goldsmith brings more than 25 years of experience to her practice, representing health care providers such as hospitals, home health agencies and skilled nursing facilities. She provides advice on Medicare and Medicaid reimbursement and regulatory issues involving conditions of payment and conditions of participation. Ms. Goldsmith's diverse experience includes issues involving PPS, provider-based status, wage index, bad debt, quality data, medical education (GME, IME, Nursing and Allied Health), DSH, and cost allocation, as well as billing and claims issues, the Two-Midnight rule, quality reporting, telemedicine, 340B and Medicare bundled payments.