Both the Department of Justice and the Department of Health and Human Services Inspector General have long urged (and in many cases, mandated through settlements that include Corporate Integrity Agreements and through court judgments) that health care organizations have “top-down” compliance programs with vigorous board of directors implementation and oversight. Governmental reach only increased with
Board of Directors / Governance
Three Critical Components of Every Hospital Merger You Need to Understand
Every hospital merger has three critical components that board members and senior management need to consider, and which can provide a great analytic framework within which to evaluate options early in the process of consider a transaction. By no means are these three the most important in every transaction, but every hospital merger I’ve worked…
Community Hospitals: Know Your Constituents and Stakeholders Before Starting Down the Path to Merger
Organizations considering a significant transaction have a lot to think about. One of the most important is making certain that relationships with key constituents and stakeholders are appropriately maintained and managed. Too frequently, community hospitals and community health systems underestimate the scope and importance of those relationships.
Most of us can rattle-off a short list…
CMS Final Rule Revising Conditions of Participation of Hospitals
In the latest application of the law of unintended consequences….
As you may know, on May 16, 2012, CMS issued a final rule revising the conditions of participation by hospitals in the Medicare and Medicaid programs. (Download the final rule.) Among other things, the final rule includes a provision requiring that at least…