Regulatory Framework for Vendor Arrangements with Hospitals - McDermott

Demystifying the Regulatory Framework for Vendor Arrangements with Hospitals – A Three Part Series

Overview


Hospital and health systems rely on vendors and other partners to provide vital services that support patient care, efficient operations and smooth administrative functions. However, the regulations governing different types of arrangements with hospitals are complex and can often present unexpected pitfalls.

In this three-part webinar series, our regulatory attorneys will examine the practical implications for vendors and other entities working directly with hospitals, hospitals working with other providers through the “under arrangement” rule, and organizations navigating the intricacies of co-location agreements. This engaging series is a must-attend for hospitals and health systems, clinical services vendors and management companies, digital health companies, and any clinical entity providing services at a hospital campus or within a hospital’s physical structure.

Setting Up Successful Vendor Arrangements Under the Medicare Provider-Based Rule
Register here | February 10, 2022 | 12:30 pm – 1:30 pm ET

Finding the right partner is only the first step. Before signing a contract, you need to make sure the planned arrangement is actually permitted under the Medicare provider-based rule. This rule defines the services eligible to be billed as hospital services—and that definition varies based on several key factors, including the type of health system and the location where the services are furnished.

Our legal panelists will explore:

  • The important distinctions that hospitals, vendors, contractors and hospital affiliates need to understand in order to bill services appropriately
  • The requirements that providers must meet in order to retain more favorable reimbursement
  • The recent uptick in government scrutiny of provider-based arrangements including recent enforcement under the provider-based rule.

Unpacking & Understanding the Medicare “Under Arrangement” Rules
Register here | February 15, 2022 | 12:30 pm – 1:30 pm ET

To ensure that patients receive the care that they need, a hospital may arrange for another entity to provide a particular service to a patient. In this type of contract arrangement, a complicated set of Medicare reimbursement rules comes into play and dictates how such services may be billed.

In this session, we will walk through the nature of “under arrangement” billing between health systems and provide:

  • Guidance on how funds should—and should not—flow according to the nature of the arrangement
  • Tips for establishing appropriate oversight and control over services being provided and billed “under arrangements”
  • Practical case studies.

On Location: New CMS Hospital Co-Location Guidance in the Spotlight
Register here | February 17, 2022 | 12:30 pm – 1:30 pm ET

Particularly thorny regulatory issues arise when a hospital shares space, services or staff with another provider. Further complicating matters, the guidance historically provided by the Centers for Medicare and Medicaid Services (CMS) has not always been clear or consistent. Recently, CMS issued new guidance that sheds more light on the subject.

In this session, we’ll offer insights into the current regulatory environment and how it might continue to evolve, including:

  • What’s new in CMS’s November 2021 final guidance on hospital co-location and space-sharing arrangements
  • The most common issues that crop up when external provider services are offered on a hospital’s property
  • How vendor contracts work under co-location agreements
  • Enforcement trends.

Dig Deeper

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