Bolstered by the Supreme Court's landmark decision in National Federation of Independent Business v. Sebelius, 132 S.Ct. 2566 (June 28, 2012), the movement toward affiliation as a means of improving ...

Earlier this year, Congress passed the Consolidated Appropriations Act (“CAA”), which imposes two new requirements on hospitals that operate off-campus, provider-based clinics. These hospitals must ...

Medicare reimbursement for hospital outpatient services has come under attack in recent years, with a focus on “site neutral” payment policies that would pay hospitals for outpatient services ...

HHS’ Office of Inspector General recently released a report detailing vulnerabilities in CMS’ oversight of billing at provider-based facilities. The report investigated a random sample of 333 ...