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CMS Rescinds Prior Administration's EMTALA Guidance on Emergency Abortions

The Centers for Medicare & Medicaid Services (CMS) has rescinded its 2022 guidance and accompanying letter that reinforced hospitals' obligations under the Emergency Medical Treatment and Labor Act (EMTALA) to provide...more

HHS Previews Guidance Addressing Implementation of 340B Rebate System

In the fall of 2024, several pharmaceutical companies reacted to HRSA's decision to prevent them from implementing a rebate model for their respective 340B Programs by filing lawsuits against HHS and HRSA claiming that the...more

Trump's Executive Order Targets 340B Drug Pricing Program

President Trump issued an Executive Order on April 15, 2025, titled "Lowering Drug Prices by Once Again Putting Americans First," with the express goal of providing Americans and taxpayers access to prescription drugs. One...more

HHS and HRSA Defend 340B Discount Model Against Pharma Rebate Plan

Summary of Changes - In the fall of 2024, several pharmaceutical companies – specifically, Eli Lilly and Company, Sanofi-Aventis U.S. LLC, Bristol Myers Squibb Company, and Novartis Pharmaceuticals Corporation – reacted to...more

CMS Enacts New CLIA Regulations Effective January 2025

On December 23, 2023, CMS issued its Final Rule, establishing new Clinical Laboratory Improvement Amendments (CLIA) regulations (the Final Rule). Several provisions only became effective December 28, 2024. CMS was driven to...more

2025 Medicare Physician Fee Schedule: Payment and Overpayment Policies

On December 9, 2024, the Centers for Medicare & Medicaid Services' (CMS's) Calendar Year 2025 Physician Fee Schedule Final Rule (the Final Rule) was published in the Federal Register. The Final Rule includes noteworthy...more

Significant Changes Affecting Hospitals in CMS's FY 2025 IPPS Final Rule

CMS published its FY 2025 Medicare Hospital Inpatient Prospective Payment System (IPPS) final rule on August 1, 2024. Under this final rule, CMS is implementing several changes to its Hospital Inpatient Quality Reporting...more

CMS Proposes Significant Changes to the Medicare Shared Savings Program and 60-Day Rule

Under the CY 2025 Medicare Physician Fee Schedule (PFS) proposed rule, CMS proposes several modifications to the Medicare Shared Savings Program (MSSP) that would become effective in performance year 2025. CMS also proposed...more

CMS Proposes Extending COVID-Era Telehealth and Supervision Flexibilities through CY 2025

The Centers for Medicare & Medicaid Services (CMS) proposed to extend a number of COVID-era regulatory flexibilities related to telehealth, remote services, and supervision in the CY 2025 Medicare Physician Fee Schedule (PFS)...more

How to Comply with HHS' New Nondiscrimination Compliance Infrastructure Requirements in Your Facility

The U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services and Office of the Secretary (collectively, HHS) released on May 6, 2024, the agencies' Final Rule governing the implementation of...more

HHS Finalizes Health Care Nondiscrimination Provisions in Section 1557 Final Regulation

The U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services and the Office of the Secretary (collectively, HHS) released the agencies' Final Rule governing the implementation of Section 1557 of...more

2024 Medicare Physician Fee Schedule Final Rule Extends COVID-19 Telehealth Policies and Includes Bonus Extension

The CY 2024 Medicare Physician Fee Schedule Final Rule (Final Rule) implemented several statutory extensions to COVID-19 telehealth waivers and flexibilities, finalized proposed policies, and extended an important telehealth...more

Reproductive Privacy Rights: Changes Coming for Health Care Organizations

On April 17, 2023, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) published a Proposed Rule to support reproductive health care privacy in the Federal Register. Through the...more

While the Public Health Emergency (PHE) is Projected to End May 11, Medicare Telehealth Coverage Expansions Were Extended Through...

President Biden recently announced that his administration plans to end the COVID-19 PHE on May 11, 2023. This provides more clarity about the long-anticipated end date for certain telehealth waivers and enforcement...more

HHS to Provide Roadmap for Behavioral Health Integration

On September 14, 2022, the U.S. Department of Health and Human Services (HHS) published its Roadmap for Behavioral Health Integration outlining how HHS plans to advance President Biden’s national strategy to address mental...more

CY 2023 Medicare PFS Final Rule Relaxes Supervision Requirements for Incident To Behavioral Health Services

On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) issued its 2023 Physician Fee Schedule Final Rule (Final Rule). The Final Rule made several noteworthy changes, including expanding access to covered...more

Noteworthy Telehealth and Remote Services Provisions in the CY 2023 Medicare PFS Final Rule

On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) Final Rule. This article highlights noteworthy provisions of the Final Rule...more

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