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Photo of Posts by Arthur E. Peabody, Jr. Arthur E. Peabody, Jr.
Of Counsel
apeabody@health-law.com
202.580.7710
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Showing 2 posts by Arthur E. Peabody, Jr..

Hooper, Lundy & Bookman, P.C. (HLB) wants to make hospitals aware of current adjustments being imposed by certain MACs denying reimbursement for Medicare bad debts for the alleged failure to maintain “continuous” collection efforts during the 120-day period following the issuance of a bill to the patient for unpaid co-pay and deductible amounts. MACs are asserting that a patient is more likely to pay these amounts during the 120-day period, so continuous efforts are allegedly required to meet the obligation of hospitals to engage in a “genuine, rather than token collection effort,” in accordance with PRM-I, §310.  Read More ›

Hooper, Lundy & Bookman, P.C. (HLB) wants to make hospitals aware of current adjustments being imposed by certain MACs denying pass-through treatment of allied health program costs, including nursing, pharmacy and pastoral care. The denial of pass-through treatment is based on the view of some MACs that any administrative involvement by a home office means that the hospital does not appropriately incur the costs of the allied health program and do not, as a result, comply with 42 C.F.R §413.85(f).  We expect that this improper practice could spread to other MACs.

This is improper because nearly all hospital chains use a home office to perform administrative functions for their hospitals, such as processing payroll, and these costs are allocated to each of the hospitals in the chain.  Such functions, and the allocation of various administrative costs, does not mean that a hospital does not operate, control, or incur the costs of its allied health programs.  The denial of pass-through treatment of allied health programs also is improper because it reverses long-standing agency policy that has been in place since at least 1984, without appropriate authority. Read More ›

For media assistance, please contact Maura Fisher at 202-580-7714.