Brick Gentry P.C. is pleased to announce the relaunch of our Healthcare Law Update, a monthly publication designed for Iowa’s healthcare providers, including hospitals, clinics, rural health systems, behavioral health organizations, physician groups, and individual practitioners.

Beginning January 2026, our healthcare practice group will provide regular insights on key legal and regulatory developments affecting healthcare entities and providers across the State of Iowa. Each monthly update will feature:

  • Regulatory and compliance changes, including HIPAA, Stark/AKS, telehealth, reimbursement, credentialing, and licensing.
  • Litigation trends and notable case developments impacting healthcare providers.
  • Federal and state guidance relevant to Iowa’s hospitals, clinics, physician groups, behavioral health providers, and individual practitioners.
  • Practical considerations for administrators, executives, and boards.
  • Hands-on considerations necessary to navigate healthcare contracts.

As state and federal requirements continue to evolve, our goal is to offer clear, Iowa-focused guidance that helps organizations and individuals navigate operational and legal challenges throughout 2026 and beyond.

We welcome suggestions from healthcare leaders and partners regarding topics of interest for future updates. Please contact us with questions or ideas.

– Paul Drey & Emily Reiners

Brick Gentry, P. C., and the Iowa Healthcare Law Blog are excited to announce that Emily Reiners is now a shareholder with Brick Gentry and will be a key contributor to the Iowa Healthcare Law Blog.  Emily brings her past healthcare experience from her time as an attorney in private practice and at Unity Point.  She brings a keen understanding of regulatory and compliance law issues in the healthcare arena, as well as superior skills in drafting and reviewing healthcare contracts and advising healthcare professionals in Iowa.  Her approach and knowledge of the important issues make her a trusted advisor to those with whom she works.  We are so pleased that she is now part of our Brick Gentry Healthcare Team.

MACRA’S QUALITY PAYMENT PROGRAM HAS GONE LIVE – ACTION REQUIRED IN 2017 TO AVOID PART B PAYMENT REDUCTIONS IN 2019 – QPP BASICS TO KNOW IN GETTING STARTED

A new Congress has convened, a new administration is at the helm, and repeal of the Affordable Care Act (ACA) is on the docket, an action of consequence for, among other things, the Medicare Shared Savings Program (MSSP), primary care medical homes, and other Medicare-developed alternative payment models (APMs). On the other hand, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), establishing a Medicare Part B Quality Payment Program (QPP), is bipartisan legislation of little debate. The American Medical Association, the American Hospital Association, and over 100 other health care entities have appealed to the Administration to preserve value-based care.  https://www.premierinc.com/wp-content/uploads/2017/01/Jan-25-letter1-24-17-Administration.pdf. So, even in the midst of ACA uncertainty, MACRA and its QPP are moving forward. The Centers for Medicare and Medicaid Services (CMS), by rule, has developed a QPP structure that went live on January 1, 2017.

Continue Reading MACRA’s Quality Payment Program Has Gone Live

Medicare/Medicaid Reform and ACA Repeal on the Horizon, MACRA Moves Forward for Now

The new administration’s agenda for health care may have come into clearer focus with President-Elect Donald Trump’s nomination of House Representative Tom Price, MD, a Republican from Georgia, as Secretary of Health and Human Services (HHS) and Seema Verma, MPH, as CMS Administrator. The American Medical Association (AMA) released a statement of strong support for Congressman Price, encouraging a swift confirmation vote. “Dr. Price,” the AMA said, “has been a leader in the development of health policies to advance patient choice and market-based solutions as well as reduce excessive regulatory burdens that diminish time devoted to patient care and increase costs.”

Continue Reading President-Elect Trump Names Rep. Tom Price, MD (R-GA) as HHS Secretary, Seema Verma, Health Care Consultant, as CMS Administrator

QRUR Informal Review Also Available.

Physicians and other eligible professionals and practices who failed to meet criteria for satisfactory PQRS reporting in calendar year (CY) 2015 now face a negative 2% adjustment in Medicare Part B payments for CY 2017. Physicians who believe CMS has inappropriately determined that a negative PQRS payment adjustment applies to them have until November 30* to request an informal review.  CMS set forth the following instructions for requesting an informal review.  *Deadline for requesting informal review of VM calculations now extended to December 7, 2016.

Continue Reading Time Remains to File a request for Informal Review of CY 2017 PQRS Negative Payment Adjustment

On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) released its final rule implementing the new Quality Payment Program for physicians in lieu of the repealed sustainable growth rate factor (SGR). Rather than facing substantial annual reductions in Medicare payment fees as a result of the SGR, physicians now have two interrelated pathways to earn quality-based, cost efficient incentive payments under Medicare:  the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (Advanced APMs). MIPS consolidates three existing quality-based incentives programs – the Physician Quality Reporting System (PQRS), the Physician Value-based Payment Modifier (VM), and the Medicare Electronic Health Record (EHR) Incentive Program – while maintaining an ongoing focus on achieving quality and cost efficiencies through use of certified EHR technology (CEHRT).

Continue Reading CMS publishes Final MACRA Rule for MIPS and APM Incentives

Physicians subject to the Rule must meet notice and posting obligations by October 16, 2016.

The federal Department of Health and Human Services (HHS), through its Office for Civil Rights (OCR), has published its final Rule implementing Section 1557 of the Affordable Care Act (ACA), 42 U.S.C. 18116, prohibiting discrimination in health care programs and activities. The new Rule, like Section 1557, specifically focuses its prohibitions and requirements on four already existing federal nondiscrimination laws: 1) Title VI of the Civil Rights Act of 1964, prohibiting discrimination based on race, color and national origin; 2) the Age Discrimination Act of 1975; 3) Section 504 of the Rehabilitation Act of 1973; and, 4) the sex discrimination provisions of Title IX of the Education Amendments of 1972 (extended by Section 1557 to health care). Section 1557 is in addition to rights and remedies available under these four laws. While the nondiscrimination prohibitions of Section 1557 have been in effect since passage of the ACA in March of 2010, this final Rule advises health care consumers of their Section 1557 rights and informs affected health care programs and activities of their Section 1557 obligations.

Continue Reading Hhs’ Final Nondiscrimination Rule Impacts Most Physicians

CMS proposed rule details Medicare’s new physician “Quality Payment Program”

Reporting under new measures slated to begin in 2017

The Centers for Medicare & Medicaid Services (CMS), the federal agency responsible for Medicare payment to physicians, released a proposed rule on April 27, 2016, setting forth key provisions of its Quality Payment Program for physicians, implementing key provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA repealed the Sustainable Growth Rate (SGR) formula for annually adjusting Medicare payment to the nation’s physicians, replacing the SGR with a value-based payment system to be developed by CMS consistent with MACRA’s directives. The proposed rule has been published in the May 9, 2016 Federal Register. Comments are due by June 27, 2016.

Continue Reading MACRA on the Move!

2016 Amendments Permit Disclosure for Care Coordination Only Under State Law

One of the more challenging aspects of medical records management are federal and state legalities around release of substance abuse and mental health patient information. This year, the Iowa General Assembly passed legislation, Senate File 2144, to permit disclosure of otherwise confidential behavioral health information under Iowa law for care coordination purposes. SF 2144 was signed by Governor Branstad on April 6 and became effective on that day.

Continue Reading Iowa Legislature Amends Behavioral Health Disclosure Laws

Even so, employers are best protected in giving statutory notice and medical providers are best protected in assuring that continued care remains authorized.

Notification requirements imposed by Iowa’s workers’ compensation law upon employers authorizing care for an injured employee took center stage in a recent decision of the Iowa Supreme Court. In that case, Ramirez-Trujillo v Quality Egg, L.L.C., et. al. (No. 14-0640, filed April 15, 2016), an employee suffered back injuries from a slip and fall at work. The employer acknowledged the workplace injury and authorized care through a care provider selected by the employer. The employee received treatment for acute low back pain and muscle spasms until the authorized provider released the employee to return to full duty work without restrictions. Weeks later, however, the employee returned to the authorized care provider for additional treatment for acute low back pain and muscle spasms over a period of several months.

Continue Reading Iowa Supreme Court Crafts An Avenue Of Relief For Employers Who Fail To Notify Injured Workers That Medical Care Is No Longer Authorized