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HHS Requests FCC Opinion on Whether Certain Telephonic Communications are Permissible Under the Telephone Consumer Protection Act

On April 28, 2022, in a joint letter written by the HHS Secretary, Xavier Becerra, and CMS Administrator, Chiquita Brooks-LaSure, to the Chairwoman of the Federal Communications Commission (FCC), HHS requested an opinion...more

CMS Proposes New DMEPOS Coverage Policies and Payment Rates, and Seeks to Codify HCPCS Application, Benefit Category and Payment...

On November 4, 2020, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule (the Proposed Rule) outlining proposals for the coverage and payment for durable medical equipment, prosthetics, orthotics, and...more

HRSA Implements Administrative Dispute Resolution Process for 340B Program

On December 10, 2020, HRSA issued a final rule (the Final Rule) implementing the 340B Drug Pricing Program administrative dispute resolution (ADR) process–an overdue mandate from the Affordable Care Act. Under the Final...more

CMS Announces New Funding, Training, and Staff Testing Requirements for Nursing Homes

On July 22, 2020, CMS announced four new policies pertaining to nursing homes during the COVID-19 public health emergency. First, CMS allocated to nursing homes an additional $5 billion from the Provider Relief Fund...more

Sixth Circuit Upholds Validity of Medicare Audit Despite Lack of Notice, Citing Lack of Substantial Prejudice

On June 24, 2020, the U.S. Court of Appeals for the Sixth Circuit issued an opinion addressing whether an overpayment assessment should be invalidated when the Medicare contractor fails to provide notice of a post-payment...more

CMS and ONC Release Interoperability and Patient Access Final Rules

On March 9, 2020, CMS released its final rule creating certain interoperability and patient access standards (CMS Final Rule). On the same day, the ONC released a rule that addressed interoperability as well (ONC Final...more

CMS Issues Medicare Advantage and Part D Proposed Rule for Contract Year 2021 and 2022

On February 5, 2020, CMS issued a proposed rule advancing multiple updates and changes to Medicare Advantage (MA) and Medicare prescription drug benefit (Part D) programs (Proposed Rule). Unlike in past years, CMS will not...more

CMS Issues CY 2020 End-Stage Renal Disease / Durable Medical Equipment Final Rule

On October 31, 2019, CMS issued a final rule (the Final Rule) that updates payment policies and rates under the End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) effective for calendar year (CY) 2020 and makes...more

CMS Announces that Current DMEPOS CBP Contracts Will Not Be Renewed or Extended for January 2019, and Proposes Changes to the...

On July 11, 2018, CMS announced that the process for recompeting contracts with suppliers currently in effect under the durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) Competitive Bidding Program (CBP)...more

CMS Releases First “Rural Health Strategy”

On May 8, 2018, CMS released its first “Rural Health Strategy.” The Rural Health Strategy focuses on the following five objectives to achieve CMS’s vision for rural health: (i) applying a “rural lens” to CMS policies; (ii)...more

CMS Updates National Coverage Determination for Implantable Cardioverter Defibrillators

On February 15, 2018, CMS released a final policy decision updating the national coverage determination (NCD) governing implantable cardioverter defibrillator (ICD) implantation for Medicare fee-for-service patients. In this...more

CMS Requests Dismissal of Its Nursing Home Arbitration Appeal

On June 2, 2017, CMS filed a motion to dismiss its appeal to the U.S. Circuit Court for the Fifth Circuit of a U.S. District Court decision blocking the agency’s ban on mandatory nursing home arbitration. CMS’s motion did...more

CMS Announces New Standardized Voluntary Self-Referral Disclosure Protocol Forms

On March 27, 2017, CMS posted a new set of standardized forms for disclosure of potential violations of the Stark Law under the Self-Referral Disclosure Protocol (“SRDP”). The forms instruct disclosing entities to follow...more

D.C. District Court Dismisses a Hospital’s Challenge of Another Hospital’s Failure to Provide Wage Documentation to CMS

On March 21, 2017, the U.S. District Court for the District of Columbia ruled that a hospital lacked standing to challenge a decision of the Provider Reimbursement Review Board (the “PRRB”), since the hospital failed to...more

CMS Releases Online Tool to Facilitate Incorporation of MACRA Measures in Clinicians’ Software

On November 17, 2016, CMS released three application program interfaces (APIs) that make it easier to analyze the Medicare Access and CHIP Reauthorization Act of 2015 Quality Payment Program (QPP) measures and to build...more

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