Client Alerts

Recently, the Department of Community Health (DCH) published an updated Pharmacy Services Provider Manual with additional billing instructions for all 340B drug claims. DCH used this update to consolidate prior guidance and provide additional information on 340B Program participation and prevention of duplicate discounts. For 340B Outpatient Pharmacy (Retail Pharmacy) Claims, DCH now requires [...]

The Bipartisan Budget Act of 2018 extends the relaxed qualifying criteria for the low volume hospital payment adjustment through September 30, 2018.  Under the relaxed criteria, the payment increases are applicable for hospitals that have less than 1,600 Medicare discharges (including traditional and Medicare Advantage) and are located more than 15 road miles from [...]

In a memorandum dated March 12, 2018, from John Upchurch, the Georgia Department of Community Health (DCH) communicated the process of the State Fiscal Year 2018 Nursing Home Upper Payment Limit (UPL) payments for the 1st through 3rd quarters.  The transfer amounts and gross nursing home UPL funds are available on the DCH website:  [...]

In a memorandum dated January 25, 2018, from John Upchurch, the Georgia Department of Community Health (DCH) announced it is seeking approval from the Centers for Medicare and Medicaid Services (CMS) to expand the Physician UPL program to include the following: All physician practices affiliated with a public teaching hospital enrolled in Georgia Medicaid. [...]

Organizations subject to Unrelated Business Income (UBI) Tax at corporate rates will now pay a flat tax rate of 21%. However, for taxable years beginning after December 31, 2017 multiple UBI activities can no longer be aggregated.  Instead, the income or loss from each activity is separately calculated and loss activities can no longer [...]

For taxable years beginning after December 31, 2017 an excise tax of 21% is imposed on compensation exceeding $1 million paid to any of an organization’s covered employees and to any excess parachute payments paid to any covered employees.   The excise tax applies to any employee that was one of the 5 highest paid [...]

The last step for hospitals receiving calendar year 2017 Tax Credit donations is an annual report to the State.  The 2017 Rural Hospital Tax Credit Donation and Expenditure Report must be submitted to the Georgia Department of Community Health no later than February 1, 2018. The form is available at the following website: https://dch.georgia.gov/rural-hospital-tax-credit. [...]

While many of us were preparing to ring in the New Year, U.S. District Judge Rudolph Contreras ruled that CMS’s nearly 30% payment reduction on certain 340B purchased drugs could take effect as planned.  Judge Contreras ruled that the lawsuit to block these cuts could not be justified until hospitals presented specific claims for [...]

The fiscal year (FY) 2016 Hospice Wage Index and Payment Rate Update final rule included a change to align the inpatient and aggregate cap accounting year with the federal fiscal year of September 30 beginning in FY 2017.  This change moves the due date to file a self-determined inpatient and aggregate cap determination from [...]