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Substance Use Disorder Treatment Services: 2025 Physician Fee Schedule Proposed Rule Would Expand Access and Medicare Coverage

On July 10, the Centers for Medicare & Medicaid Services (CMS) released the Medicare Physician Fee Schedule Proposed Rule (Proposed Rule) for the calendar year 2025. The Proposed Rule would implement certain provisions of the...more

Behavioral Health: CMS Innovation Model Outlines Changes for the Delivery of Integrated Behavioral and Physical Health Care

On January 18, 2024, the Centers for Medicare & Medicaid Services (CMS) announced a new innovation model designed to improve quality of care and behavioral and physical health outcomes for Medicaid and Medicare patients with...more

CMS Expands Access to Behavioral Health Services; Physician Fee Schedule Expands Billing Providers and Flexibilities

On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) issued its 2024 Physician Fee Schedule final rule (Final Rule) for calendar year 2024 that will, in part, implement some of the most important changes...more

2023 Medicare Physician Fee Schedule Advances Access to Whole Person Treatment for Substance Use Disorders and Behavioral Health

Starting January 1, 2023, Medicare will expand and increase coverage of certain services and providers to advance access to prevention and treatment services for substance use disorders (SUD) and mental health services. These...more

Medicare Telehealth and Substance Use Disorder Treatment FAQs: New CMS Reimbursement Requirements

In the 12-month period starting in April 2021, over 100,000 people have died from drug overdoses, a 28.5% increase from the same period the year before. While the opioid crisis has been a declared public health emergency...more

PE Firm Pays Record Settlement for Allegedly Deficient Health Services: Identifying Traps for the Unwary

In a Press Release issued on October 14 2021 by the Office of Massachusetts Attorney General Maura Healy, a potentially groundbreaking settlement was announced. Below is an excerpt from the release, followed by our takeaways....more

Stark Law Changes Coming to Physician Compensation Models in 2022

Medical groups that have division-based or service-level approaches to physician compensation should spend their summer evaluating their models in light of Stark Law revisions that go into effect on January 1, 2022. The...more

COVID-19: CMS Publishes Explanatory Guidance on Stark Blanket Waivers

As discussed in detail in a prior post, U.S. Health and Human Services Secretary Alex M. Azar II (the Secretary) issued blanket waivers of sanctions under the federal Physician Self-Referral Law (Section 1877 of the Act),...more

COVID-19: CMS Issues Temporary Blanket Waivers of Sanctions for Stark Violations; Health Care Providers Gain Needed Flexibility to...

On March 30, 2020, United States Health and Human Services Secretary Alex M. Azar II (the Secretary) exercised emergency authority under Section 1135 of the Social Security Act (Act) and issued blanket waivers of sanctions...more

340B Rate Cuts: DC Court Enjoins and Remands CMS’ 2018 and 2019 Reductions for Hospital Outpatients

On May 6, 2019, a federal district court held that the Department of Health and Human Services’ (HHS) 2018 and 2019 rate reductions for 340B Program participants, including safety net On May 6, 2019, a federal district court...more

CMS Recoupment Efforts Stopped by Court While Overpayment Appeals Are Pending

Providers and suppliers who have been assessed overpayments for Medicare services are entitled, by statute, to a stay of recoupment while the provider or supplier’s appeal is pending – but only at the first two levels of...more

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