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Medicare Payment Model Trends and Economic Drivers – Awaiting Direction from Trump Administration

The Medicare program continues to face long term financial pressures associated with inflationary effects on health care costs and the growing wave of aging baby boomers. The Medicare Trust Fund, which is often viewed as a...more

Risk Bearing Entity Requirements: An Introduction

Providers and provider organizations are increasingly contracting with payors to manage specific patient pools and diseases on a risk basis. They are taking new and increasing financial risk to better align with payors’...more

New HCPCS for Advanced Primary Care Management

The Center for Medicare & Medicaid Services (CMS) issued the display copy of the final Calendar Year 2025 Physician Fee Schedule on November 1, 2024, which included three new Healthcare Common Procedure Coding System (HCPCS)...more

The No Surprises Act: A District Court’s Decision Results in Federal IDR Outage

Although the No Surprises Act was signed into law almost three years ago and has been in effect for the past year and a half, there have been numerous delays in implementation and execution due to the complexity of elements...more

Payor/Provider Convergence and What It Means for You

Welcome to the Payor/Provider Convergence Series of the Health Care Law Today blog. This series is dedicated to exploring the intersection between payors and providers in the health care space; in particular, the evolving...more

CMS Extends Delayed Enforcement of the Good Faith Estimate

On Friday, December 2, 2022, the Centers for Medicare & Medicaid Services (CMS) issued an FAQ regarding the Good Faith Estimate (GFE) and Convening Provider/Facility requirements in the Federal No Surprises Act. The issued...more

CMS Reports Medicare Shared Savings Program Saved Medicare $1.66 Billion in 2021

On August 30, 2022, the Centers for Medicare & Medicaid Services (CMS) announced that the Medicare Shared Savings Program (MSSP) had saved the Medicare program $1.66 billion in 2021 as compared to spending targets, while...more

Proposed Revisions to Medicare Shared Savings Program: CMS Encourages Participation

The Centers for Medicare and Medicaid Services (CMS), as part of 2023 Physician Fee Schedule proposed rule, has proposed significant revisions to the Medicare Shared Savings Program (MSSP). The revisions to the MSSP in the...more

Price Transparency Enforcement is Here – Hospitals Beware

On June 7, 2022, after months of written warnings, the U.S. Centers for Medicare & Medicaid Services (CMS) has levied its first fines nationwide on two affiliated Georgia hospitals for violations of CMS’ Hospital Price...more

How does the Federal No Surprises Act Impact Telemedicine Providers? Part Two

In this second installment of this blog series on the No Surprises Act interim regulations (NSA) we discuss: i) notice and consent requirements for out of network providers providing services at participating health care...more

Sunshine Act Reporting Update: De Minimis Amounts

The Centers for Medicare & Medicaid Services (CMS) issued updated guidance on the thresholds that Applicable Manufacturers and Group Purchasing Organizations are required to report annually under the Sunshine Act (42 U.S.C. §...more

CMS Proposes Changes to Lower Drug Prices

On November 30, 2018, the Centers for Medicare & Medicaid Services (CMS) published 83 Fed. Reg. 62152, which proposes changes to Medicare Part D (prescription drug benefit) and drug plans offered by Medicare Advantage...more

CMS Continues to Tighten the Belt on Hospital Off-Campus Provider-Based Departments

Hospitals with off-campus provider-based departments (PBDs) may want to rethink their end of summer vacation plans in order to focus on a recent slate of proposed regulations from the Center for Medicare and Medicaid Services...more

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