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RubinBrown's Healthcare Consulting Newsletter: September 2026

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RubinBrown's Healthcare Consulting Newsletter: September 2026

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As summer comes to an end, September offers us time to slow down, reflect, and look forward to upcoming initiatives. RubinBrown's Healthcare Consulting Group is proud to present this month's issue that highlights key updates, ongoing priorities, and notable developments shaping the months ahead.

Blogs 

The Impact of H.R. 1 on Healthcare Providers
What does H.R. 1 mean for healthcare providers? From Medicaid eligibility changes to increased uncompensated care and reimbursement challenges, this article breaks down the key provisions and what organizations can do to prepare.

Cost Reporting as a Financial Strategy: A CFO’s Most Underleveraged Asset in Rural Healthcare
The difference between a filed cost report and an optimized one could mean hundreds of thousands of dollars in additional reimbursement. Discover why accurate Medicare and Medicaid cost reporting has become a financial lifeline for rural hospitals.

Understanding Qualified Medicare Beneficiary Coverage and Compliance Requirements for Healthcare Providers
Are your billing workflows compliant with QMB requirements? Discover how proper identification of QMB beneficiaries can help avoid costly mistakes, strengthen compliance, and improve the patient financial experience.

AI Powered: How Hackers Use Artificial Intelligence in Cyberattacks
AI is helping attackers move faster, but it isn't changing how breaches happen. Learn why organizations that focus on identity security, detection, and resilience are best positioned to withstand today's rapidly evolving cyber threats.

 

Important Updates & Deadlines 

CMS Announced an Aggressive Nationwide Crackdown with Six-Month Hospital and Home Health Agency Enrollment CMS announced a six-month nationwide moratorium on new Medicare enrollments for hospice and home health agencies, including certain changes in majority ownership, as part of a broader effort to prevent fraud before new providers enter the program. Existing providers are not affected, but CMS plans to use the moratorium period to intensify investigations, data analytics, site visits, payment suspensions, and enforcement actions against suspected fraudulent operators.

The action builds on other recent fraud-prevention efforts, including DMEPOS moratoria, hospice scoring tools, enhanced screening for high-risk home health agencies, and expanded pre- and post-claim review demonstrations in several states.

                                                                                                              

CMS’s proposed 2027 Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System rules contain significant changes affecting physician practices, hospitals and ambulatory surgery centers.

  • Under the Physician Fee Schedule proposal, conversion factors would decline from 2026 levels, while CMS is also considering changes to same-day E/M services, global procedures, G2211 and remote monitoring reimbursement.
  • The outpatient proposal includes a 2.4% payment update but would expand site-neutral payment for certain services provided in excepted off-campus hospital departments.
  • CMS is also proposing substantial changes to 340B reimbursement and the related reduction to other outpatient payments, creating potential financial exposure for participating hospitals.
  • The continued removal of procedures from the inpatient-only list could accelerate the migration of services to outpatient settings and increase the importance of patient status, utilization management and site-of-service planning.
  • Organizations should begin modeling the potential effects by service line, evaluating coding and charge-capture workflows, and considering the impact on provider compensation, outpatient strategy and overall reimbursement.

Additional information is available here.

Is Your Prior Authorization Workflow Ready for 2027 Changes?

Impacted payers generally must implement the major API requirements under CMS-0057-F by January 1, 2027. CMS has also proposed extending electronic prior authorization requirements to drugs covered under medical and pharmacy benefits, with many proposed compliance dates beginning October 1, 2027. The newer proposal would also expand requirements for specific denial reasons, decision timeframes, API information and public reporting of prior authorization metrics. 
Providers should be assessing:

  • EHR and practice management system capabilities 
  • Payer API connectivity 
  • Authorization data flowing into scheduling and billing 
  • Ownership of authorization status and expiration dates 
  • Whether payer denial reasons can be converted into actionable work queues 
  • Metrics for authorization-related delays and write-offs

Additional information can be found here

Congratulations

Join us in congratulating Julie Hardy on earning her AI Professional in Healthcare Compliance (AIP-HC) certification. This accomplishment highlights her dedication to expanding her knowledge and helping clients navigate the evolving intersection of AI and healthcare compliance.

Where You’ll Find RubinBrown

Join RubinBrown and our healthcare professionals at upcoming conferences and educational webinars designed to help providers navigate today's evolving healthcare landscape.

Webinar | October 14, 2026 I 1:00 ET
Denials as a Signal: Using Internal Audit to Strengthen Revenue Integrity
Hosted by Association of Healthcare Internal Auditors

Webinar | October 29, 2026 I 1:00 ET
RHTP: Navigating the Application & Assessment Process
Hosted by Missouri Rural Health Association
Presented by BridgeLync and RubinBrown 

Conference | November 12-13, 2026
Michigan Annual Critical Access Hospital Conference

Webinar | November 18, 2026 | 12:00 PM ET
Doing More with Less: Practical Survival Strategies and the Financial Advantage of Rural Health Clinics
Hosted by RubinBrown

Recent Webinars

Missed a Session? Here’s What You Need to Know

• The Financial Impact of H.R. 1: What Healthcare Providers Should Expect and Do Next
H.R. 1 introduces significant changes that could reshape coverage, reimbursement, and operations for healthcare providers. This session examined the law's key provisions and offered practical approaches to managing the resulting financial and regulatory challenges.

• Strategic Cost Reporting: A Guide to Optimizing Rural Reimbursement
Could your organization be leaving reimbursement dollars on the table? This webinar examined how rural hospitals and clinics can turn Medicare cost reports into a strategic asset by improving documentation, refining cost allocations, and uncovering opportunities to enhance financial performance.

If you were unable to attend any of our webinars but would like additional information, please contact Claudine Hildreth at claudine.hildreth@rubinbrown.com / 810.853.6182


 

Published: 09/01/2026

Readers should not act upon information presented without individual professional consultation.

Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.

 

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