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CMS Finalizes 340b Payment Provisions in 2023 OPPS Final Rule

Consistent with the US Supreme Court’s ruling in AHA v. Becerra and its statements in the 2023 Outpatient Prospective Payment System (OPPS) Proposed Rule, the Centers for Medicare & Medicaid Services (CMS) has finalized its...more

Healthcare Regulatory Check-Up Newsletter | August 2022 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights significant enforcement activity between July 21 and August 20, 2022. Key updates include a case in which the US Court of Appeals for the Eighth Circuit...more

White House Directs HHS to Model “Most-Favored-Nation” Price Caps for Part B and D Drugs

On September 13, 2020, the White House issued an Executive Order titled “Lowering Drug Prices by Putting America First” (the Executive Order), which directed the Secretary of the US Department of Health and Human Services...more

CMS Proposes Further OPPS Reductions to 340B Drug Reimbursement Rates

On August 4, 2020, the Centers for Medicare & Medicaid Services (CMS) released its CY 2021 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. CMS proposes to reduce OPPS payments for 340B drugs from...more

DC Circuit Upholds OPPS Reimbursement Reductions for 340B Drugs

On July 31, 2020, the US Court of Appeals for the District of Columbia Circuit held that the Centers for Medicare and Medicaid Services (CMS) has authority under the Social Security Act to reduce Medicare payment rates for...more

CMS Issues FAQs on EMTALA Requirements for Hospitals

On April 28, 2020, the Centers for Medicare and Medicaid Services (CMS) issued Frequently Asked Questions for Hospitals and Critical Access Hospitals regarding EMTALA (FAQs) as a supplement to the memorandum on the Emergency...more

CMS Releases 340B Drug Acquisition Cost Survey, Responses Due May 15, 2020

After receiving approval from the Office of Management and Budget (OMB) on April 23, 2020, the Centers for Medicare and Medicaid Services (CMS) released a survey on April 24, 2020, to collect information on 340B hospitals’...more

CMS Dramatically Modifies and Expedites the Medicare Enrollment Process to Combat COVID-19

The Centers for Medicare and Medicaid Services is expediting Medicare enrollment applications and allowing certain categories of practitioners to temporarily enroll in Medicare Part B to increase the number of healthcare...more

CMS Advances 340B Drug Acquisition Cost Survey to OMB and Solicits Final Comments Directly to OMB

On February 7, 2020, the Centers for Medicare and Medicaid Service (CMS) published a notice signaling that it has submitted its previously published September 2019 proposed survey of hospital 340B drug costs for Office of...more

GAO Recommends CMS, HRSA Improve 340B Duplicate Discount Oversight

On January 27, the Government Accountability Office (GAO) published a report concluding that the US Department of Health and Human Services (HHS) has provided limited oversight of the 340B and Medicaid Drug Rebate Programs,...more

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