Ms. Goldsmith brings more than 30 years of experience to her practice, representing health care providers such as hospitals, home health agencies, hospices and skilled nursing facilities.

She provides advice on Medicare and Medicaid reimbursement and regulatory issues involving conditions of payment and conditions of participation. Ms. Goldsmith's diverse experience includes issues involving PPS, provider-based status, wage index, bad debt, quality data, medical education (GME, IME, Nursing and Allied Health), DSH, and cost allocation, as well as billing and claims issues, the Two-Midnight rule, quality reporting, telemedicine, 340B and Medicare bundled payments.

She regularly represents clients before the Provider Reimbursement Review Board, CMS Administrator and federal courts. Ms. Goldsmith also provides advice on compliance issues related to potential overpayments and the False Claims Act involving alleged improper billing and fraudulent cost reports.

Ms. Goldsmith is the co-chair of Baker Donelson's Health Care Reimbursement Group and is co-editor of Payment Matters, Baker Donelson's publication on Medicare and Medicaid payment issues. She is the author of numerous articles on health care topics that have been published in legal and health care financial journals and is a frequent speaker at industry conferences. Nightingale’s Health Care News named her one of its ten "Outstanding Hospital Lawyers" for 2009.

Professional Honors & Activities

Professional Memberships

Member – American Bar Association
Member – American Health Law Association
Member – Maryland State Bar Association

Community Services

Maryland Chapter of the Arthritis Foundation
- Board of Directors (1998 – 2003)
- Public Policy & Advocacy Committee, Chair (1999 – 2004)
Ober|Kaler Mentoring Program
- Co-chair (2004 – 2012)

Honoraries

Recipient – JD Supra Readers' Choice Award - Top Authors in Health Law (2016 and 2017)
Selected by Nightingale's Health Care News as one of its ten "Outstanding Hospital Lawyers" (2009)

Publications

"D.C. District Court Issues Two Decisions Addressing CMS's Medicare Bad Debt "Must Bill" Policy – One Rejecting the Policy and the Other Upholding the Policy," Payment Matters (October 2019); reprinted in F2 Healthcare (November 2019)
"D.C. Court Rejects CMS's 2018 "Budget Neutrality" Policy," Payment Matters (October 2019)
"CMS Implements Enhanced Oversight of New Home Health Agencies," Payment Matters (April 2019)
"Medicare Target, Probe and Education Audits Require Immediate and Full Attention from Providers/Suppliers," Payment Matters (February 2019)
Co-author – "Provider Reimbursement Review Board Revises Rules, Effective Immediately," Payment Matters (October 2018)
Co-author – "Provider Reimbursement Review Board Revises Rules, Effective Immediately," AHLA Weekly (September 2018)
Author – "CMS Softens Physician Inpatient Order Documentation Requirement," Payment Matters (September 2018)
Author – "OIG Finds Continued Procedural Errors in Hospital Outlier Payment Reconciliations," Payment Matters (October 2017)
Co-author – "OIG Finds Acute Care Hospitals Improperly Billed for Outpatient Services Provided to Inpatients of Other Hospitals," Payment Matters (October 2017)
Author – "Court of Appeals Reverses D.D.C. Order Requiring HHS to Eliminate Medicare Appeals Backlog by December 31, 2020" (September 2017)
Author – "CMS Implements Uniform Provider-Based Checklist," Payment Matters (August 2017)
Author – "CMS Delays Implementation of Revised HHA Conditions of Participation," Payment Matters (August 2017)
Author – "CMS Proposes to Reduce Facility Payment for Non-Excepted Provider-Based Outpatient Department Services by 50 Percent," Payment Matters (August 2017)
Author – "Baker's Dozen – 13 of the Best Places to Visit in Washington, D.C," Women's Initiative Newsletter (June 2017)
Author – "Medicare Two-Midnight Rule and Observation Status Updates," Payment Matters (April 2017)
Author – "Medicare Payment Changes for 'New' Off-Campus, Provider-Based Sites – CMS Publishes Final Rule and Congress Provides Some Relief," ABA Health eSource, Vol. 13, No. 6 (February 2017)
Author – "CMS Finalizes Revamped Home Health Agency Conditions of Participation," Payment Matters (January 2017)
Chapter Editor – "First Ed., Chapter: Medicare Reimbursement – Inpatient/Outpatient Hospitals," Representing Hospitals and Health Systems Handbook, American Health Law Association (2016) [Ober|Kaler]
Author – "CMS Publishes the Medicare Outpatient Observation Notice Form and Instructions," Payment Matters (2016) [Ober|Kaler]
Author – "CMS Final Rule and 21st Century Cures Act Include Good and Bad News for Provider-Based Sites," Payment Matters (2016) [Ober|Kaler]
Author – "CMS Releases the 2016 OPPS Final Rule," Payment Matters (2016) [Ober|Kaler]
Author – "Home Health Agency PPS Update for 2017: Quality, Quality, Quality," Payment Matters (2016) [Ober|Kaler]
Author – "Court Upholds CMS's Inclusion of Part C Days in the Medicare Fraction of the DSH Calculation for FYE 2012," Payment Matters (2016) [Ober|Kaler]
Author – "D.C. District Court Strikes Down PRRB's Application of the "Self-Disallowance" Jurisdictional Requirement," Payment Matters (2016) [Ober|Kaler]
Author – "The MOON Notification is Coming: CMS Publishes Final Changes," Payment Matters (2016) [Ober|Kaler]
Author – "D.C. District Court Applies Prohibition on Administrative and Judicial Review to IRF PPS Rates," Payment Matters (2016) [Ober|Kaler]
Author – "Court Rules in Favor of Hospitals in Bad Debt Collection Effort," Payment Matters (2016) [Ober|Kaler]
Author – "Final FY 2017 Inpatient Psychiatric Facilities Payment and Policies Rule," Payment Matters (2016) [Ober|Kaler]
Author – "CMS Releases the 2017 IPPS and LTCH PPS Final Rule, Including MOON Requirements," Payment Matters (2016) [Ober|Kaler]
Co-author – "Proposed Cardiac, Hip, and Femur Episode Payment Models Are Next Generation from BPCI and CJR," Payment Matters (August 2016) [Ober|Kaler]
Author – "CMS Releases the 2016 OPPS Proposed Rule," Payment Matters (July 2016) [Ober|Kaler]
Author – "Medicare Appeals Backlog: HHS' Response to the Decade-Long Delay in Reviewing Appeals," Payment Matters (2016) [Ober|Kaler]
Author – "Home Health PPS CY 2017 Proposed Rule: Payments Rebased, Quality Measures Updated," Payment Matters (2016) [Ober|Kaler]
Author – "CMS Announces "Pause" in QIO Review of Inpatient Admissions," Payment Matters (2016) [Ober|Kaler]
Author – "CMS Limits MAC and QIC Scope of Review," Payment Matters (2016) [Ober|Kaler]
Author – "CMS's Proposed IPPS and LTCH FY 2017 Rule: Key Takeaways," Payment Matters (2016) [Ober|Kaler]
Author – "Medicare Appeals 10-Year Backlog: D.C. Circuit Signals Enough is Enough," Payment Matters (2016) [Ober|Kaler]
Author – "Court Allows 'Retroactive' Application of 2005 Wage Index Rule Limiting Reimbursement for Pension Plan Costs," Payment Matters (2016) [Ober|Kaler]
Author – "Wage Index Reclassification Rule Struck Down by Second Circuit," Payment Matters (March 2016) [Ober|Kaler]
Author – "Senate Considering Bill to Speed Medicare Claims Appeals," Payment Matters (2016) [Ober|Kaler]
Author – "2-Midnight Rule Updates," Payment Matters (2016) [Ober|Kaler]
Author – "CMS Issues CY 2016 HHA PPS, Value-Based Purchasing and Quality Reporting Final Rule," Payment Matters (2015) [Ober|Kaler]
Author – "Court Upholds HHA Face-to-Face Narrative Requirement," Payment Matters (2015) [Ober|Kaler]
Author – "CMS Proposes Significant Revisions to Hospital Discharge Planning Process: How Patient Choice May be Impacted," Payment Matters (November 2015) [Ober|Kaler]
Author – "The Bad Debt Moratorium Requires a Flexible Approach to Evaluating "Reasonable Collection Efforts"," Payment Matters (October 2015) [Ober|Kaler]
Author – "Uncertainty Continues for Two-Midnight Rule's Payment Reduction," Payment Matters (October 2015) [Ober|Kaler]
Author – "Court Upholds CMS Treatment of Multi-Campus Hospitals as Single Entities for Wage Index Purposes," Payment Matters (September 2015) [Ober|Kaler]
Author – "Home Health, CY 2016 Proposed Rule: Emphasis on Value-Based Purchasing," Payment Matters (August 2015) [Ober|Kaler]
Author – "CMS Issues CY 2016 Proposed Rule for OPPS, ASC Payment Systems and Quality Reporting," Payment Matters (July 2015) [Ober|Kaler]
Author – "CMS Proposes Limited Exception to Two-Midnight Rule and QIO Review of Short Stays," Payment Matters (July 2015) [Ober|Kaler]
Author – "CMS Pays $1.3 Billion to Hospitals for Settlements of Medicare Inpatient Appeals," Payment Matters (June 2015) [Ober|Kaler]
Author – "CMS Issues DSH Ruling 1498-R2," Payment Matters (May 2015) [Ober|Kaler]

Speaking Engagements

Presenter – "Legal Update: OIG Work Plan and Medicare Reimbursement Update," Metropolitan New York Chapter, Healthcare Financial Management Association (February 2019)
Presenter – "OIG Work Plan and Medicare Reimbursement Update," Regulatory and Reimbursement Update, Northeast Pennsylvania Chapter, Healthcare Financial Management Association (October 2018)
Presenter – "PRRB Appeals: Current Challenges," Institute on Medicare and Medicaid Payment Issues, American Health Law Association (2018)
Presenter – "OIG Work Plans and Medicare Appeals Update," Regulatory and Reimbursement Update, Northeast Pennsylvania Chapter, Healthcare Financial Management Association (October 2017)
Presenter – "OIG Work Plans and Medicare Appeals Update," Regulatory and Reimbursement Update, New Jersey Chapter, Healthcare Financial Management Association (September 2017)
Presenter – "Recent Cost Reporting Appeal Issues – PRRB and CMS Administrator Decisions," Institute on Medicare and Medicaid Payment Issues, American Health Law Association (2012 – 2017)
Presenter – "Provider-Based Reimbursement Reform," Regulatory and Reimbursement Update, New Jersey Chapter, Healthcare Financial Management Association (2016)
Presenter – "Current Hot Issues in Medicare Reimbursement," Ninth Annual Fall Institute, Philadelphia Chapter, Healthcare Financial Management Association (2015)
Presenter – "Medicare Wage Index Update," Institute on Medicare and Medicaid Payment Issues, American Health Law Association (2007 – 2010)

Press Releases