Health Law Advisor

Less than a month remains for physicians, health systems, technology companies, and other stakeholders to comment on several questions buried deep in a Request for Information (“RFI”) within the Centers for Medicare & Medicaid Services’ (“CMS”) Calendar Year 2027 Physician Fee Schedule Proposed Rule. Among them is a deceptively simple question: “What are the payment implications of including technology in primary care?”

On May 16, 2012, the Centers for Medicare and Medicaid Services of the Department of Health and Human Services (“CMS”) published regulations announcing various changes to the Medicare Conditions of Participation (“CoP”) applicable to hospitals.  According to the regulatory preamble, these revisions responded directly to the President’s “Executive Order 13563, by reducing outmoded or unnecessarily burdensome rules, and thereby increasing the ability of hospitals and [critical access hospitals] to devote resources to providing high quality patient care.”  ...