NowLeasingDeliveringClassAOfficeSpaceNovember2023

Proposed Remedy Rule prior to finalizing the CY 2024 OPPS rule this fall, with potential lump sum payments in late 2023 / early 2024. However, due to the budget neutral impact to all OPPS providers, it’s unclear if CMS will finalize the rule according to its intended schedule. We’ve summarized the major points from the Proposed Remedy Rule and areas where providers should consider submitting comments below. Comments are due by September 5, 2023.

Given the budget neutral adjustment presented by CMS, and the large volume of data used by CMS to project lump sum repayments, we anticipate significant feedback from a variety of stakeholders impacted by the Proposed Remedy Rule.

Major Points from the Proposed Remedy Rule

1. CEs Can Except to Receive a Lump Sum Repayment for 2018 – 2021 Claims. CMS proposed to pay CEs lump sum payments, which were published by CMS in Addendum AAA. The total repayment amount for the lump sum accounts for $9B of the total $10.5B proposed. As proposed, neither CMS nor CEs would need to pursue adjusted coinsurance payments. CEs should verify the amounts published align see Legal Matters ...page 14