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Payment Matters
January 26, 2011
February 12, 2011 Deadline to Protest FY 2011 Wage Index Data
A hospital that wishes to challenge its FY 2011 Medicare wage index as published in the August 16, 2010 Federal Register, must file an appeal at the Provider Reimbursement Review Board (PRRB) by February 12, 2011. The current PRRB Rules and Model Forms necessary to file an appeal can be found at www.cms.gov/PRRBReview/02_PRRB_Instructions.asp. Even if your hospital does not object to your own wage data that was used to compute your area’s wage index, you should strongly consider joining any other hospital in your wage index area that is appealing regarding corrections to its own wage data, in order to gain the benefit of a higher wage index, should the other hospital be successful in its appeal.
Click to continue...Supreme Court Upholds IRS Rule that Hospitals Must Pay FICA Taxes on Resident Stipends
By: Mark A. Stanley
The United States Supreme Court issued its decision this month in Mayo Foundation for Medical Education v. U.S. [PDF], No. 09-837 (Jan. 11, 2011), upholding IRS regulations that treat medical residents as employees, as opposed to students. As a result, teaching hospitals must pay FICA taxes on their residents’ earnings. The Mayo Foundation opinion brushes aside precedents that constrained agency rulemaking authority, and thereby further entrenches the Court’s deferential approach to judicial review of agency rulemaking, which was announced in Chevron U.S.A. v. National Resources Defense Council, 467 U.S. 837 (1984).
Click to continue...HIT Policy Committee Releases Proposed Stage 2 (and Stage 3) Meaningful Use Requirements; Requests Public Comment
By: James B. Wieland and Joshua J. Freemire
Health care providers who have begun preparations for meaningful use attestations (and are planning to receive the associated incentive payments) should take note that the Stage 2 criteria are currently under development. Providers interested in participating in the standard setting process should review the proposed Stage 2 recommendations [PDF] recently released by the Health Information Technology Policy Committee (HITPC) and comment before the February 25, 2011 close to the comment period. Comments may be submitted electronically (through www.regulations.gov) or via mail or hand delivery to the Office of the National Coordinator for Health Information Technology's (ONC) District of Columbia offices.
Click to continue...CMS Implements Value-Based Payment System for Dialysis Facilities
By: Susan A. Turner
The Centers for Medicare & Medicaid Services (CMS) issued a final rule [PDF] on December 29, 2010 that establishes performance standards for dialysis facilities and providers (e.g., hospital-based dialysis programs) (collectively, "facilities" for this article), and provides payment adjustments to individual End-Stage Renal Disease (ESRD) facilities based on how well they meet these standards. The ESRD Quality Incentive Program (QIP) links CMS payments directly to facility performance on certain quality measures.
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