At The Podium
Hospitals Under the CMS Microscope: The New Primarily Engaged in Inpatient Service Standards and Scrutiny of Provider-Based Departments
Speaking at the American Health Lawyers Association’s 2018 In-House Counsel Program and Annual Meeting in Chicago on June 26, 2018, healthcare attorney Patricia Rogers is joined by Teresa Williams, vice president of regulatory services for INTEGRIS Health, to discuss the Centers for Medicare & Medicaid Services’ ramped-up enforcement of its requirement that hospitals be “primarily engaged” in providing inpatient services in order to be qualified as a hospital under the Social Security Act. Noncompliance with this requirement can result in the termination a hospital’s Medicare provider agreement.
- The “primarily engaged” in inpatient services criteria and the risks of non-compliance
- Section 602 site-neutral provider-based regulations for new off-campus hospital departments
- The exceptions under Section 602 for dedicated emergency services, remote locations of hospitals, and other expansion opportunities
- Leasing and time-share arrangements in provider-based space
- Ongoing compliance tips