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The One Big Beautiful Bill Act Explained: A Detailed Review of Key Changes for the Healthcare Industry

To offset the cost of other provisions in the bill, the One Big Beautiful Bill Act (OBBBA) includes significant reforms to Medicaid, Medicare, and Affordable Care Act (ACA) premium tax credits that are expected to result in...more

United States District Court in Florida Holds False Claims Act Qui Tam Provision Unconstitutional

On September 30, 2024, a federal district court in Florida held the qui tam enforcement provision of the False Claims Act (“FCA”), which permits private citizens to pursue actions in the name of and on behalf of the...more

Sixth Circuit’s Defendant-Friendly Opinion Joins Circuit Split on Anti-Kickback Statute Pleading Standard

On March 28, 2023, the Sixth Circuit issued a decision interpreting the definition of remuneration under the Anti-Kickback Statute (AKS) and the level of causation necessary for a False Claims Act (FCA) action to be premised...more

CMS Announces Increased Scrutiny for Poor-Performing Nursing Facilities

On October 21, 2022, CMS announced new actions to increase accountability and scrutiny on nursing homes in the Special Focus Facilities Program (SFF Program), an oversight program for the poorest performing nursing homes in...more

OIG Issues Favorable Advisory Opinion Regarding Non-Profit Efforts to Provide Financial Assistance and Free Items to Individuals...

On May 2, 2022, OIG posted Advisory Opinion 22-10, regarding a proposal to provide financial assistance and free items to individuals with a particular disease. The Requestor, a non-profit organization dedicated to providing...more

OIG Report Analyzes Payments in Excess of Hospice Per Diem Rate

Last week, OIG released a report analyzing trends in the last decade relating to Medicare payments for hospice beneficiaries outside of the hospice per diem. In the report, OIG notes that CMS has taken the position that...more

HHS Distributes Additional $2 Billion in Provider Relief Fund Payments

Last week, HHS announced the distribution of more than $2 billion in Provider Relief Fund (PRF) Phase 4 General Distribution payments. These payments bring the Phase 4 distribution total to approximately $11 billion of the...more

Don’t Be Surprised – The No Surprises Act Takes Effect January 1, 2022

The No Surprises Act (the Act), enacted December 27, 2021, will take effect on January 1, 2022. The No Surprises Act puts into place important patient protections from surprise medical bills, while imposing significant...more

CMS Issues Four Payment Rules for FY 2022

On July 29, 2021, CMS issued final rules for FY 2022 in its yearly update to Medicare payment policies under the Skilled Nursing Facility (SNF) prospective payment system (PPS), Inpatient Rehabilitation Facilities (IRFs) PPS,...more

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