With all the recent focus on the Affordable Care Act, providers need to remember the increased resources for enforcement and the need to ensure regulatory compliance at every turn. One trap for the unwary health care provider is the failure to document your arrangements with referral sources: simply put, any arrangement that involves a reasonable, fair market value payment for a necessary service must be documented appropriately.
On July 9, 2012, the Centers for Medicare and Medicaid Services (“CMS”) posted 43 frequently asked questions (“FAQs”) addressing various issues concerning the 3-day Payment Window Rule (the “Rule”). As background, the Rule applies to outpatient services furnished (1) by a hospital or (2) by another Part B supplier (referred to herein as a “Physician Practice”) that is wholly-owned or operated by a hospital. Under the Rule, the admitting hospital must bundle the technical component of all outpatient diagnostic services and related non-diagnostic services with t
For 20 years beginning in the 1960s, IBM was king of its universe: the mainframe computer. Then came along such interesting start-ups as Microsoft, Intel and Dell and, as personal computers became more powerful, IBM’s mainframe business could no longer support the company. Like healthcare providers today, IBM had the choice of transforming itself or going the way of the dinosaurs.
Regardless of the brilliant strategy or the fantastic business plan – if the people in a business deal “don’t work”, then the deal won’t work. Savvy hospitals and physician groups understand this phenomenon as they approach negotiation. Their conduct facilitates a good outcome and an environment in which the new relationship can create value in their merged approach to the business of healthcare.