How effective has the hospital been in the structuring of “bundled” payments when compared to the actual costs of episodes of care?
What is the count for “licensed” beds vs. the number of beds which could actually be occupied at “peak” capacity?
What is the payor mix? What is the percentage of Medicare, Medicaid, third party insurance, high deductible patients, private pay and/or uninsured?
Is there a history of underpayments, slow or delayed payments by third party administrators (TPAs) (which processes insurance claims or aspects of employee benefit plans)? Is the reimbursement rate similar to that of competitors?
Is revenue being lost to ambulatory centers, outpatient facilities, area hospital systems or specialty clinics? Are the number and type of competitors increasing, changing or static?
What is the status under the Hospital Readmissions Reduction Program which reduces reimbursement rates for “excess” patient readmissions?
Is there a pharmacy? If so, is it owned by the facility or operated by a third party?
Is there a fragile patient population? If so, how long will it take to transfer all patients? How long will it take to stop admitting new patients?
Is there an emergency room? If so, what is the process for diversion?
Is there leased equipment? Can the equipment be moved?
Who will take responsibility for the patient records? What is the cost for storage of records? Who will notify former patients regarding the location of their records?
Are there land use restrictions? Can any restrictions be easily modified?
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.