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CMS Finalizes The Increasing Organ Transplant Access Model

The Increasing Organ Transplant Access Model ("IOTA Model") introduces mandatory financial incentives and penalties for selected kidney transplant hospitals....more

HHS Finalizes New AKS Safe Harbors for Patient Engagement and CMS-Sponsored Arrangements

The Situation: As health care providers transition to value-based care models, they have often been forced to rely on safe harbors under the Anti-Kickback Statute, or AKS, that were never designed with value-based payment...more

Health Care on the Other Side: Changing Payer-Provider Relationships in a Post-COVID-19 Landscape

Hospitals, physician practices, and other provider organizations are dealing with unprecedented challenges in the present public health emergency following the spread of the novel coronavirus (COVID-19). Providers can expect...more

A Dramatic Shift in Health Care Pricing Transparency

The Issue: On June 24, 2019, President Trump signed an executive order, which instructed the Department of Health and Human Services to publish rules requiring hospitals to publicly disclose their negotiated rates for...more

CMS Proposed Rule Would Expand Coverage of Telehealth Benefits Under Medicare Advantage

The Situation: Earlier this year, Congress passed the Bipartisan Budget Act of 2018 ("BBA"), which expands coverage for telehealth in Medicare Advantage ("MA") plans beginning in 2020. The Update: The Centers for Medicare...more

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