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Fifth Circuit Finds No Private Right of Action for Providers to Enforce Surprise Billing Awards

On Thursday, June 12, 2025, a panel of the United States Court of Appeals for the Fifth Circuit issued two rulings construing parts of the No Surprises Act (NSA) to limit judicial review of arbitration awards issued under the...more

OIG Issues Special Fraud Alert Regarding Marketing Payments Related to Medicare Advantage

On December 11, 2024, OIG issued a Special Fraud Alert to warn the industry about the fraud and abuse risks associated with abusive Medicare Advantage (MA) organization (MAO) and agent and broker relationships with healthcare...more

HHS Releases Notice of Benefit and Payment Parameters 2023 Proposed Rule

On December 28, 2021, HHS released a proposed rule governing plans issued in the Patient Protection and Affordable Care Act (ACA) marketplaces beginning with the 2023 plan year (the Proposed Rule). Among other changes to the...more

HHS Launches New Reimbursement Program for COVID-19 Vaccine Administration Fees Not Covered by Insurance

On May 3, 2021, HHS announced a new program to cover the costs of COVID-19 vaccination for patients enrolled in health plans that either do not cover vaccinations generally, or cover them but with patient cost-sharing...more

HHS Extends Comment Period on Proposed HIPAA Rule

On January 21, 2021, the HHS Office for Civil Rights (OCR) published a notice of proposed rulemaking (the Proposed Rule) proposing modifications to the HIPAA Privacy Rule to address standards that might impede the transition...more

CMS Announces CMMI Milestones and Updates

CMS recently announced updates and milestones for several programs run by the Center for Medicare and Medicaid Innovation (CMMI). CMMI is the internal CMS agency responsible for developing and testing new health care payment...more

CMS Proposes New Radiation Oncology Model

On July 10, 2019, CMS announced a new proposal for episode-based payment for radiation oncology services. The aim of this new proposal is to determine whether episode-based payment to hospitals, physician groups, and...more

Trump Signs Executive Order Calling for Increased Transparency and Upfront Disclosure of Hospital Charges and Out-of-Pocket Costs

On Monday, June 24, 2019, President Trump issued an executive order requiring HHS and other agencies to propose regulations designed to promote transparency and upfront disclosure by hospitals to patients of the charge prices...more

CMS Announces Final Rules for Medicare Advantage Telehealth Benefits

On April 5, 2019, CMS issued final rules (the Final Rule) implementing various provisions of the 2018 Bipartisan Budget Act (the 2018 Budget). The 2018 Budget includes provisions allowing Medicare Advantage plans to provide...more

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