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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: The Departments Proposed Another Increase to IDR Fee, Will it Stick?

On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...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

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

Compliance Officers Lookout! DOJ and OIG Tag Team Corporate Integrity Agreements

The Office of Inspector General of the U.S. Department of the Health and Human Services (OIG) recently changed the language describing a compliance officer’s role in relation to other responsibilities he or she may have...more

No Surprises Act Challenges, Win for Providers

On Wednesday, February 23, 2022, U.S. District Court Judge Jeremy Kernodle of the Eastern District of Texas granted the Texas Medical Association’s and Adam Corley’s (the Plaintiffs) motion for summary judgment on their...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

Government Issues No Surprises Act Interim Final Rule with Comment Period (Part II)

On September 30, 2021, the U.S. Departments of Health and Human Services (HHS), Labor and Treasury (collectively, the Departments) along with the Office of Management and Budget released “Requirements Related to Surprise...more

Federal Government Publishes an Interim Final Rule (Part 1) Implementing the No Surprises Act

Over the last several years, both the federal government and a number of state legislatures have sought to find a solution to the billing by out-of-network providers, referred to as “Out of Network Billing” (OON Billing) and...more

Drug Pricing: White House Announces Withdrawal of Proposed Changes to Anti-Kickback Safe Harbors

On July 11, 2019, the Trump administration announced it would withdraw a proposed rule that would eliminate the Anti-Kickback Statute (AKS) safe harbor that protected rebates made from pharmaceutical manufacturers to pharmacy...more

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