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“One Big Beautiful Bill Act”

On July 4, 2025, President Trump signed into law H.R. 1, "One Big Beautiful Bill Act" (the “Act” or “OBBBA”) a comprehensive bill that combines many of the President’s major policy initiatives he had promised during his...more

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

President Trump Signs Budget Reconciliation Bill with Significant Medicaid Changes into Law

On the afternoon of July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act – comprehensive budget reconciliation legislation that represents the core of President’s second-term domestic agenda and...more

Senate Finance Committee Releases Budget Bill with More Aggressive Medicaid Provider Changes Than House Version

On June 16, 2025, the U.S. Senate Finance Committee released draft legislative language for its version of the “One Big Beautiful Bill Act,” a comprehensive budget reconciliation proposal that includes significant changes to...more

House Passes Reconciliation Bill Impacting Medicaid Financing, Programs, and Eligibility

On May 22, 2025, the House passed H.R. 1, the One Big Beautiful Bill Act (the Bill), its budget reconciliation legislation that upheld most of the Medicaid-related provisions originally approved by the House Energy and...more

Budget Reconciliation Bill Impacts Medicaid Financing, Programs, and Eligibility

Last week, the House Energy & Commerce Committee marked up legislation that would significantly affect the Medicaid program, including changes to state Medicaid financing mechanisms, state directed payment programs that...more

House Republicans Intend to Tie GME Training Funds to Ban Gender Affirming Care

House Republicans have announced their intent to cut federal funding for training new pediatricians to hospitals that perform gender-affirming care on minors. The proposed bill, sponsored by Rep. Dan Crenshaw (R-Texas), would...more

CMS Issues Guidance for Medicare Contractors to Pay For Section 1115 Day

On March 16, 2023, CMS issued Change Request 12669, which contains instructions for Medicare Administrative Contractors (MACs) to begin the process of retroactively reimbursing DSH hospitals for inpatient days attributable to...more

Supreme Court Ruling in AHA v. Becerra May Affect 340B Hospitals' Reimbursement Rights Against Medicare Advantage Plans

Hospitals that participate in the 340B program may be entitled to additional monies from Medicare Advantage plans in the wake of the Supreme Court’s decision in AHA v. Becerra. In AHA v. Becerra, a unanimous Supreme Court...more

CMS Proposes for the Third Time to Exclude Section 1115 Uncompensated Care Pool Days from Medicare DSH

On February 24, 2023, CMS issued a proposed rule that would modify the Medicare Disproportionate Share Hospital (DSH) payment regulation to limit the universe of Section 1115 demonstration beneficiaries who can be “regarded...more

CMS Announces Initiatives to Strengthen Nursing Home Safety and Transparency

On January 18, 2023, CMS issued a Quality, Safety & Oversight Group memorandum announcing its initiative to improve nursing home safety and transparency. Specifically, CMS will conduct audits to determine whether nursing...more

CMS to Resume Enforcement of COVID-19 Vaccination Mandate for Healthcare Workers in Jurisdictions Not Covered by Federal...

On December 28, 2021, CMS announced that it would resume enforcement of its COVID-19 vaccine mandate for healthcare providers in areas not covered by injunctions issued by federal courts. As of December 15, 2021, federal...more

Supreme Court to Review Federal COVID-19 Vaccine Mandates in Early January

Last Wednesday, the U.S. Supreme Court announced it would hear oral arguments on January 7, 2022, regarding the legality of two federal COVID-19 vaccine mandates issued under the Biden administration. The justices will be...more

Injunction Prohibiting CMS Enforcement of COVID-19 Vaccine Mandate for Healthcare Workers Partially Lifted, Potentially Opening...

On Wednesday, December 15, 2021, the Fifth Circuit Court of Appeals denied the federal government’s petition for a stay pending appeal of the preliminary injunction issued by a federal district court in Louisiana that...more

Biden Administration Unveils New COVID-19 Vaccination and Testing Requirements for Large Businesses and Healthcare Workers

On November 4, 2021, the Biden administration published two new rules governing employers with 100 or more employees and healthcare workers at hospitals, nursing homes and other facilities that participate in Medicare and...more

CMS Releases Mid-Build Off-Campus Outpatient Department Audit Results

On January 19, 2021, CMS announced the results of its audit of off-campus outpatient departments claiming the “mid-build” exception following enactment of the 21st Century Cures Act (the Cures Act). Of the 334 providers that...more

CMS Proposes Quality Program Changes, Increased OPPS and ASC Medicare Payments for 2021

On August 4, 2020, CMS proposed its annual rule adjusting the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System, as well as changes to quality reporting...more

CARES Act: Medicare Advanced Payment Protocol

The federal government has implemented a number of relief programs in response to the COVID-19 public health emergency. Many borrowers in the healthcare industry may be seeking funds under the recently-expanded Medicare...more

CARES Act: Public Health and Social Services Emergency

King & Spalding’s Healthcare Finance practice is working to keep clients informed of issues that may be of concern to lenders in the healthcare space. The CARES Act includes a number of provisions to offer financial relief to...more

CMS Releases Section 1135 Waiver in Response to the Novel Coronavirus Pandemic

On March 13, 2020, President Trump declared the coronavirus pandemic a national emergency, invoking powers under the National Emergency Act and the Stafford Act. The President’s declaration, coupled with Secretary Azar’s...more

CMS to Repay Hospitals for 2019 Off-Campus Clinic Visit Services

CMS and its contractors have announced that beginning January 1, 2020, the agency will repay hospitals for underpaid evaluation and management (E/M) services provided in excepted off-campus provider-based departments during...more

CMS Extends Timeline to Finalize Updated Medicare Rules for Hospitals to June 2020

In 2016, CMS issued a proposed rule to update the requirements that hospitals and critical access hospitals must meet to participate in Medicare and Medicaid programs....more

What Next for the ACA after Texas v. U.S.? What the Industry Needs to Know While the Case Is on Appeal

United States District Court Judge Reed O’Connor of the Northern District of Texas issued a ruling on Friday, December 14, 2018, declaring the Patient Protection and Affordable Care Act (ACA) unconstitutional in its entirety....more

D.C. Circuit Clears the Way for Hospitals to Challenge Base-Year Factual Determinations

The United States Court of Appeals for the District of Columbia Circuit recently held in Saint Francis Medical Center v. Azar that Medicare’s reopening regulation, which prohibits providers from seeking to revise payment...more

2018 Proposed Rules: Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System

On July 13, 2017, CMS issued the Calendar Year (CY) 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System (ASCPS) proposed rule (Proposed Rule). CMS proposes to update OPPS...more

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