"Questionable" guidance.

CMS's recent FAQs on how GME/IME payments will be managed for residents' training in nonhospital settings only add to healthcare providers' confusion on this issue. Several recommendations represent substantial changes in the rules. The new requirements that are expressed or implied in the FAQs make compliance extremely difficult.

Medicare implications of discounts to the uninsured.

Discount policies are likely to face increased scrutiny in light of congressional inquiries on Medicare outlier payments and recent media attention regarding pricing for the uninsured. If you're considering making changes to your hospital's policy, you'll need to understand the current regulatory environment, recognize potential concerns, and develop a plan of action that complies with recent HHS guidance.