Thomas W. Coons
Bar Admissions
- District of Columbia
- Maryland
- Virginia
Court Admissions
- Court of Appeals of Maryland
- Court of Appeals of the District of Columbia
- Supreme Court of Virginia
- United States Court of Appeals for the District of Columbia Circuit
- United States Court of Appeals for the Fifth Circuit
- United States Court of Appeals for the Fourth Circuit
- United States Court of Appeals for the Ninth Circuit
- United States Court of Appeals for the Seventh Circuit
- United States Court of Appeals for the Third Circuit
- United States Supreme Court
Education
- Georgetown University Law Center (J.D., 1972)
- Law Fellow
- Journal of Law & Policy in International Business, Editor
- University of Tennessee (B.S., 1969)
Thomas W. Coons
Newsletters
CMS's Non-Hospital Training Rules Again Upheld, Payment Matters
May 3, 2012
By: Thomas W. Coons
CMS Reminds Providers of How Reasonable Cost Principles Apply to Provider Taxes, Payment Matters
April 19, 2012
By: Thomas W. Coons
CMS Issues Revised 2006-2009 SSI Percentages, Payment Matters
April 3, 2012
By: Thomas W. Coons and Mark A. Stanley
CMS's New Application of an Old Policy: The Three-Day Payment Window and Wholly Operated Physician Practices, Payment Matters
November 9, 2011
By: Thomas W. Coons
CMS Provides Further Adjustments to Hospital Outpatient Supervision Rules
November 9, 2011
By: Thomas W. Coons
Accreditation of Advanced Diagnostic Imaging Suppliers Must Be Completed by January 1, 2012, Payment Matters
October 13, 2011
By: Thomas W. Coons
Hospitals Suffer Setback in IME Research Case, Payment Matters
September 1, 2011
By: Thomas W. Coons
CMS Issues GME/IME Resident Cap Adjustments, Payment Matters
August 18, 2011
By: Thomas W. Coons
CMS Proposes Physician Payment Reductions for Services Within Hospital Three-Day Payment Window, Payment Matters
July 27, 2011
By: Thomas W. Coons
CMS Proposes Refinement of Outpatient Supervision Rules for Therapeutic Services, Payment Matters
July 27, 2011
By: Thomas W. Coons
Reminder: CMS Now Permits Electronic Submission of Medicare Graduate Medical Education (GME) Affiliation Agreements
June 28, 2011
By: Thomas W. Coons
Recent GME/IME Case: Proceed with Caution in Use of Stipulations, Payment Matters
March 29, 2011
By: Thomas W. Coons
CMS Releases Final Rule for IME/GME Provisions in the Health Care Reform Legislation, Payment Matters
December 9, 2010
By: Thomas W. Coons and Mark A. Stanley
CMS's Outpatient Supervision Rules – A Moving Target, Payment Matters
November 18, 2010
By: Thomas W. Coons
Court of Appeals Rules for Hospital in IME Research Case: The Battle Continues, Payment Matters
September 10, 2010
By: Thomas W. Coons
Is She a “Resident” or a “Billing Physician”? CMS Issues Needed Clarification, Payment Matters
August 27, 2010
By: Thomas W. Coons
CMS Proposes Additional Changes to the Outpatient Physician Supervision Requirements, Payment Matters
August 13, 2010
By: Thomas W. Coons
CMS Releases Proposed Rule for IME/GME Provisions in the Health Care Reform Legislation, Payment Matters
July 30, 2010
By: Thomas W. Coons and Mark A. Stanley
CMS Proposes a Policy Clarification Regarding Medicare Treatment of Medicaid Provider Taxes, Payment Matters
June 10, 2010
By: Carel T. Hedlund and Thomas W. Coons
CMS Giveth and Taketh Away: New CMS Ruling on Medicare DSH Payments, Payment Matters
May 13, 2010
By: Thomas W. Coons
District Court Reaffirms Decision in Favor of Hospitals that Split Costs for Training Residents at a Nonhospital Site, Payment Matters
February 4, 2010
By: Thomas W. Coons and Mark A. Stanley
Eastern District of Michigan Rejects Secretary's Position on IME/Research Time and New Residency Programs, Payment Matters
January 21, 2010
By: Thomas W. Coons and Joshua J. Freemire
IME Research Time Revisited: Court Requires CMS to Explain Criteria, Payment Matters
January 6, 2010
By: Thomas W. Coons
CMS Releases 2010 Payment Rules for Services Furnished in Hospital Outpatient Departments and Ambulatory Surgical Centers, Payment Matters
December 3, 2009
By: Thomas W. Coons and Mark A. Stanley
Another District Court Rejects Hospitals' DSH Claims, Payment Matters
October 29, 2009
By: Thomas W. Coons and Joshua J. Freemire
Medicare DSH Reimbursement for Charity Care Dealt Another Blow, Payment Matters
October 15, 2009
By: Thomas W. Coons and Joshua J. Freemire
District Court of Michigan Deals Blow to Non-Hospital Site Provider Education, Payment Matters
October 1, 2009
By: Thomas W. Coons and Joshua J. Freemire
The Divide Continues: Illinois Court Rejects Secretary's Interpretation of IME Regulation to Exclude Research Time, Payment Matters
September 17, 2009
By: Thomas W. Coons and Kristin Cilento Carter
CMS Imposes Significant Limitations on "New" Medical Education Programs Qualifying for IME/GME Reimbursement, Payment Matters
September 2, 2009
By: Thomas W. Coons
Court Offers Mixed Decisions on Medical Education Reimbursement for Managed Care Patients, Payment Matters
August 18, 2009
By: Thomas W. Coons and Mark A. Stanley
One Court Upholds Medicare "Written Agreement" Requirement for GME/IME, Payment Matters
July 31, 2009
By: Thomas W. Coons and Mark A. Stanley
CMS Proposes to Both Ease and Tighten Physician Supervision Requirements for Hospital Outpatient Services, Payment Matters
July 15, 2009
By: Thomas W. Coons
CMS to Rescind Final "Clarification" of Medicaid Outpatient Hospital Services Definition, Payment Matters
June 2, 2009
By: Thomas W. Coons and Joshua J. Freemire
CMS's Proposed Rule on Hospitals' "New" GME Programs Would Restrict Reimbursement for Such Programs, Payment Matters
June 2, 2009
By: Thomas W. Coons
Providers' Outpatient Blended Rate Challenges Rejected, Payment Matters
May 14, 2009
By: Thomas W. Coons
Deadline Approaches for Resolution of Baystate DSH/SSI Case, Payment Matters
April 9, 2009
By: Thomas W. Coons and Mark A. Stanley
Clarity Is Hard to Find: CMS's CY 2009 "Clarification" Regarding Physician Direct Supervision Requirement for Hospital Outpatient Department Services Raises More Questions than it Answers, Payment Matters
January 23, 2009
By: Thomas W. Coons and Mark A. Stanley
Final "Clarification" of Medicaid Outpatient Hospital Services Definition Issued; Will be Challenged by AHA, Payment Matters
January 8, 2009
By: Thomas W. Coons and Joshua J. Freemire
First Circuit Adopts CMS' Interpretation of IME Regulation to Exclude Research Time, Payment Matters
December 10, 2008
By: Thomas W. Coons and Kristin Cilento Carter
CMS Issues Final Outpatient PPS Regulations, Payment Matters
November 12, 2008
By: Thomas W. Coons and Lisa D. Stevenson
CMS Issues Proposed Outpatient PPS/ASC Payment Update, Payment Matters
August 6, 2008
By: Thomas W. Coons and Mark A. Stanley
Be Careful What You Assume: CMS Issues Latest Clarification of Physician Supervision Rules in Hospital Outpatient Departments, Payment Matters
August 6, 2008
By: Susan A. Turner and Thomas W. Coons
No Longer Final: CMS Proposes Review of Some DAB Decisions, Health Law Alert
Summer 2008
By: Thomas W. Coons
D.C. Appeals Court Reverses Favorable Decision on Charity Care Days in Adena Regional Medical Center v. Leavitt, Payment Matters
June 26, 2008
By: Thomas W. Coons and Joshua J. Freemire
Beware of Overpayments in a CHOW Situation, Payment Matters
June 11, 2008
By: Thomas W. Coons
Government Reaches $666 Million Settlement in Medicare Reimbursement Case, Payment Matters
March 18, 2008
By: Thomas W. Coons
Significant Changes Proposed for DAB, Payment Matters
January 9, 2008
By: Kristin Cilento Carter
CMS Issues Final Policy and Payment Changes for Hospital Outpatient Services, Payment Matters
November 12, 2007
By: Thomas W. Coons, Leslie Demaree Goldsmith, and Carel T. Hedlund
CMS Alters Medicare Payment Structure for ASCs, Payment Matters
August 15, 2007
By: Thomas W. Coons
CMS Issues Final FY 2008 IPPS Rate and Policy Changes, Payment Matters
August 15, 2007
By: Carel T. Hedlund, Thomas W. Coons, and Leslie Demaree Goldsmith
Medical Education Under Medicare: Confusion over Didactic Time, Health Law Alert
Summer 2007
By: Thomas W. Coons
Providers Score a Victory in DSH Litigation, Health Law Alert
Spring 2006
By: Thomas W. Coons
More GME Guidance on Nonhospital Sites, Health Law Alert
Fall 2005
By: Thomas W. Coons
New Changes to Medicare Medical Education Rules, Health Law Alert
Fall/Winter 2004
By: Thomas W. Coons
New Confusion in GME/IME Off-Site Training Rules, Health Law Alert, Spring/Summer 2004
Spring/Summer 2004
By: Thomas W. Coons
Provider-based Rules Take Effect, Health Law Alert
Fall/Winter 2003
By: Thomas W. Coons
