The Centers for Medicare & Medicaid Services (“CMS”) recently proposed certain changes to the existing satellite facility rules in its Inpatient Prospective Payment System (“IPPS”) and Long Term Acute Care Hospital (“LTCH”) Prospective Payment System proposed rule for fiscal year 2019. In this episode, Darlene Davis discusses the effect of these changes, if implemented as proposed, on the current separateness and control requirements for satellite facilities and the similarities between this proposal and CMS’ changes to the hospital within a hospital rules effective in 2017.

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