Long Term Care Hospitals and Inpatient Rehabilitation Hospitals

We represent Long Term Care Hospitals (LTCH) and Inpatient Rehabilitation Hospitals (IRF), and provide counsel on regulatory compliance and operational matters related to LTCHs and IRFs, including physician contracting. In addition, we have assisted LTCHs and IRFs in developing successful compliance programs, overseeing legal reviews of compliance issues, internal audits, and legally privileged independent audits, as well as assisting with overpayment and other compliance disclosures to government agencies.

We have advised LTCH providers on LTCH-specific issues such as the LTCH prospective payment system (LTCH PPS) and its payment adjustments, including the 25% Rule, high cost outliers, short stay outliers, and interrupted stay payments, as well as operational issues such as the LTCH bed moratorium and rules concerning hospitals-within-hospitals, satellite facilities, remote locations, and provider-based entities. We have assisted IRF providers with issues related to the 75/25 Rule and the IRF Conditions of Payment.

Finally, we have assisted LTCH and IRF providers in the development and acquisition of new hospitals and new hospital locations, and have provided guidance relating to the regulatory issues that accompany such transactions.

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