Jeffrey Davis on Health Insurance

Health Plans’ Commitment to Prior Authorization Improvements: What’s New Versus What’s Already Required

Health plan members of AHIP and the Blue Cross and Blue Shield Association made news earlier this week when they announced a series of steps that a broad swath of health insurers will take to improve the prior authorization...more

6/26/2025 / Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Health Insurance , Healthcare , Healthcare Reform , Insurance Industry , Medicare Advantage , New Regulations , Prior Authorization , Regulatory Reform , Regulatory Requirements

Breaking Down the New No Surprises Act FAQs Post-TMA III (June 2025 Update)

UPDATE: On May 30, 2025, the Fifth Circuit granted the TMA III plaintiffs’ petition for rehearing en banc, which was previously filed on December 16, 2024. Of note, the Fifth Circuit’s mandate has not yet been issued, so as a...more

6/9/2025 / Appeals , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Dispute Resolution , Health Insurance , Healthcare Reform , Litigation Strategies , No Surprises Act (NSA) , Statutory Interpretation

First Steps in Implementing the Trump Administration’s Price Transparency Agenda

Recently, the Trump administration took steps toward implementing one of its major priorities: improving price transparency. As discussed in a previous Regs & Eggs blog post, President Trump signed an executive order (EO) on...more

5/29/2025 / Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Drug Pricing , Executive Orders , Health Insurance , Healthcare Reform , Hospitals , Price Transparency , Regulatory Reform , Rulemaking Process , Trump Administration

Sound of Silence? What the CMS Innovation Center’s Announcement Does and Doesn’t Say

The Centers for Medicare & Medicaid Services (CMS) Innovation Center made headlines last week by announcing that it would end eight models early. The Innovation Center put out a fact sheet explaining its rationale behind...more

3/20/2025 / Centers for Medicare & Medicaid Services (CMS) , Executive Orders , Health Care Providers , Health Insurance , Healthcare Reform , Medicaid , Medicare , Regulatory Agenda , Regulatory Requirements , Trump Administration

Breaking Down the New No Surprises Act FAQs Post-TMA III

On January 14, 2025, the US Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments), along with the Office of Personnel Management (OPM), jointly issued Part 69 of a series of...more

3/18/2025 / Centers for Medicare & Medicaid Services (CMS) , Cost-Sharing , Department of Health and Human Services (HHS) , Disclosure Requirements , Dispute Resolution , Final Rules , Health Care Providers , Health Insurance , Healthcare , Healthcare Reform , Medicaid , New Guidance , No Surprises Act (NSA) , Regulatory Requirements , Trump Administration

Trump Administration Executive Order Tracker

Below is a tracker of healthcare-related executive orders (EOs) issued by the Trump administration, including overviews of each EO and the date each EO was signed. We will regularly update this tracker as additional EOs are...more

3/7/2025 / Compliance , Department of Health and Human Services (HHS) , Executive Orders , Federal Contractors , Health Insurance , Healthcare , Healthcare Reform , Regulatory Agenda , Regulatory Requirements , Trump Administration

The Future of Medicare Advantage: Q&A with McDermott+’s Lynn Nonnemaker

A few weeks ago, Regs & Eggs provided insights into Medicare Advantage (MA), the private insurance option under Medicare, and explored both short- and long-term actions that the Trump administration could take to modify MA...more

2/13/2025 / Centers for Medicare & Medicaid Services (CMS) , Health Insurance , Healthcare , Healthcare Reform , Insurance Industry , Medicare , Medicare Advantage , Medicare Part D , Proposed Rules , Regulatory Agenda , Trump Administration

Outlook for Medicare Advantage Under the Trump Administration

Medicare Advantage (MA), the private insurance option under Medicare, is one of many policy areas that will garner great attention in 2025 and beyond under the incoming Trump Administration. We recently released our 2025...more

1/16/2025 / Centers for Medicare & Medicaid Services (CMS) , Enrollment , Final Rules , Health Insurance , HRA , Legislative Agendas , Medicare , Medicare Advantage , Proposed Rules , Trump Administration

ACO REACH: What Recent Performance Results Could Mean for the Model’s Future

Decisions, decisions, decisions. The Centers for Medicare & Medicaid Services (CMS) under the Trump Administration will have its hands full making decisions about Center for Medicare and Medicaid Innovation (CMMI) models...more

12/5/2024 / ACOs , Alternative Payment Models (APM) , Biden Administration , Centers for Medicare & Medicaid Services (CMS) , CMMI , Health Care Providers , Health Insurance , Healthcare , Healthcare Reform , Medicaid , Medicare , Medicare Shared Savings Program , Trump Administration

It’s the Final Countdown: Comparing the Last Regulatory Actions of the Biden and Trump Administrations

The election is approaching fast, and no matter who wins, there will be a change in administration come January 20, 2025. Thus, the Biden Administration is in the midst of making its final mark on priority healthcare...more

10/24/2024 / Biden Administration , Centers for Medicare & Medicaid Services (CMS) , Health Insurance , Healthcare , Kamala Harris , Legislative Agendas , Proposed Legislation , Proposed Regulation , Regulatory Agenda , Trump Administration

Regs Coming Through the End of the Year: Expect the Expected and the Unexpected

There could be an all-you-can-eat buffet of regs (and eggs) from now until the end of the year! As you may recall, a July 2024 Regs & Eggs blog post highlighted the spring 2024 “unified agenda” that listed all the regs...more

10/17/2024 / Biden Administration , Billing , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Dispute Resolution , Health Care Providers , Health Insurance , Healthcare , Healthcare Reform , Legislative Agendas , Medicare Advantage , Proposed Regulation , Regulatory Agenda , Regulatory Standards

CMMI’s Accountable Care Strategy: A Perspective

McDermott+ is pleased to bring you Regs & Eggs, a weekly Regulatory Affairs blog by Jeffrey Davis. Click here to subscribe to future blog posts. October 10, 2024 – For several years, the Center for Medicare & Medicaid...more

10/11/2024 / ACOs , Affordable Care Act , Centers for Medicare & Medicaid Services (CMS) , CMMI , Health Care Providers , Health Insurance , Healthcare , Medicaid , Medicare , REACH

CMS Issues Guidance to States on Children’s Access to Medicaid Coverage

Last week, the Center for Medicaid and CHIP Services within the Centers for Medicare & Medicaid Services (CMS) released what it calls “historic” guidance to states on best practices for adherence to early and periodic...more

10/3/2024 / Centers for Medicare & Medicaid Services (CMS) , Children's Health Insurance Program (CHIP) , Department of Health and Human Services (HHS) , Health Insurance , Healthcare , Healthcare Reform , Medicaid , New Regulations , Regulatory Agenda

HHS, Labor, and Treasury Finalize Mental Health Parity Rule

On September 9, 2024, the US Departments of Health and Human Services (HHS), Labor, and the Treasury (collectively, the Departments) finalized a rule titled Requirements Related to the Mental Health Parity and Addiction...more

9/18/2024 / Department of Health and Human Services (HHS) , Department of Labor (DOL) , Employee Benefits , Health and Welfare Plans , Health Insurance , Mental Health , Mental Health Parity Rule , MHPAEA , NQTLs

CMS Releases Final TCET Notice – Implications and Next Steps

Last week, the Centers for Medicare & Medicaid Services (CMS) issued a final procedural notice for the new Transitional Coverage for Emerging Technologies (TCET) pathway for certain US Food & Drug Administration (FDA)...more

8/15/2024 / Centers for Medicare & Medicaid Services (CMS) , Emerging Technologies , Food and Drug Administration (FDA) , Health Insurance , Healthcare , Legislative Agendas , Medical Devices , Medicare , New Legislation , Regulatory Agenda

Regs, Regs and More Regs: The Biden Administration Releases Spring 2024 Unified Agenda

We are in the midst of a storm of regulations that are being released by the Centers for Medicare & Medicaid Services (CMS) and the US Department of Health and Human Services (HHS), including the Calendar Year (CY) 2025...more

7/11/2024 / Biden Administration , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Health Care Providers , Health Insurance , Healthcare , Healthcare Reform , Hospitals , Insurance Industry , Legislative Agendas , Medicare Advantage , Popular , Proposed Regulation , Regulatory Agenda

CMS Finalizes Major Reforms to Medicaid, Part 2: Medicaid Managed Care Reg

Medicaid Regs Part 2! Last week, Regs & Eggs took a deep dive into the Ensuring Access to Medicaid Services final reg, one of two regs that the Centers for Medicare & Medicaid Services (CMS) released to add new requirements...more

5/3/2024 / Affordable Care Act , Centers for Medicare & Medicaid Services (CMS) , Children's Health Insurance Program (CHIP) , Fee-for-Service , Health Care Providers , Health Insurance , Health Insurance Exchanges , Healthcare , Managed Care Contracts , MCOs , Medicaid , Price Transparency , Proposed Regulation

Another News-Filled Medicare Advantage Regulatory Week

Although I previously declared January 2024 Medicare Advantage (MA) Month, this week has also been filled with news about the MA program. The Centers for Medicare & Medicaid Services (CMS) released the final rate announcement...more

4/4/2024 / Centers for Medicare & Medicaid Services (CMS) , Congressional Committees , Health Care Providers , Health Insurance , Healthcare , Legislative Agendas , Medicare , Medicare Advantage , Medicare Part C , Medicare Part D , MedPAC

Regs During an Election Year: What’s on the Menu?

Last week, McDermott+Consulting launched an election 2024 resource page, where you can find a 2024 health policy outlook and other insights into the November election. While regulations aren’t necessarily top-of-mind when...more

1/25/2024 / Biden Administration , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Drug Pricing , EMTALA , Health Insurance , Healthcare , Healthcare Reform , Managed Care Contracts , Medicare , Medicare Advantage , Medicare Part D , OMB , Pharmaceutical Industry , Prescription Drugs , Reproductive Healthcare Issues

Jeffrey Davis

McDermott Will & Emery

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