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Baker's Dozen: What Does Leaving a Legacy Mean to You?

What does it mean to leave a legacy? For some, it’s about mentorship and creating opportunities for those who follow. For others, it’s about building relationships, shaping a culture of inclusion, or making a lasting impact...more

CMS Proposes New Payment Model for Some Kidney Transplant Programs

In its continuing efforts to improve the organ donation and transplant system and promote health equity, the U.S. Department of Health and Human Services (HHS), acting through the Centers for Medicare and Medicaid Services...more

The Joint Commission Establishes Certification to Reflect Hospitals' Dedication to Equitable Care

Effective July 1, 2023, The Joint Commission (TJC) is accepting applications from eligible hospitals and hospital systems for its Health Care Equity (HCE) Certification program. By way of background, TJC generally accredits...more

Initiative to Modernize National Organ Transplant System

On March 22, 2023, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services, launched the Organ Procurement and Transplantation Network Modernization Initiative...more

HHS Seeks to "Address Gaps" in Section 1557 Rule with New Proposed Rulemaking

On August 4, 2022, the U.S. Department of Health and Human Services (HHS) published in the Federal Register a notice of proposed rulemaking (NPRM) designed to "address gaps" in prior iterations of one of the agency's civil...more

Advancing Health Equity in Transplantation: New Waitlist Policies Require Race-Neutral Data

As both the Senate and House continue their investigations into the organ transplant system (see Senate investigation and House investigation), and given the Biden Administration's ongoing focus on achieving health equity via...more

CMS Considers Comprehensive Changes to Organ Donation and Transplantation System Through RFI

As part of its continuing efforts to improve the organ donation and transplantation system, the Centers for Medicare and Medicaid Services (CMS) recently issued a Request for Information (RFI) seeking public comments on...more

CMS Continues to Consider Organ Acquisition Cost Rule Changes

In response to the Centers for Medicare & Medicaid Services' (CMS's) proposed changes to Medicare's organ acquisition payment policies proffered in the Medicare Hospital Inpatient Prospective Payment System (IPPS) Proposed...more

Employers and Health Care Providers Take Note: Recent Announcements Forecast Increased Government Enforcement of Discrimination...

The law regarding discrimination on the basis of "sex" continues to evolve rapidly. Perhaps sparked by last year's landmark discrimination ruling in the Bostock case and by President Biden's day-one Executive Order on...more

Newly Proposed Rule Regarding Organ Acquisition Payment Policies

On April 27, 2021, CMS issued its Fiscal Year 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospital (LTCH) Rates Proposed Rule (CMS-1752-P), in which it proposes several changes to...more

DOJ Finds Certain Hospital Transplant Policies Violate the ADA – Transplant Centers Should Take Note

The Department of Justice (DOJ) recently reached a settlement agreement with a Massachusetts hospital under Title III of the Americans with Disabilities Act (ADA) to resolve claims that its transplant consideration process...more

New HHS Guidance on Solid Organ Transplantation: Reducing Risk and Increasing Availability

Organ procurement organizations (OPOs) and transplant centers should take note: as expected, and as outlined in our recent organ procurement and transplant alert, the U.S. Department of Health and Human Services (HHS)...more

Organ Transplant Rates Remain Low: What Hospitals Need to Know to About Their Obligation to Help

It may come as no surprise that, in the wake of the COVID-19 pandemic, the national organ transplantation rate has plummeted. Despite CMS's recently published guidance identifying transplants as Tier 3b procedures that should...more

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