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CMS Announces Proposed $9 Billion Remedy for Hospitals Underpaid by Unlawful Rate Cut for 340B Drugs

On July 7, 2023, CMS published its highly-anticipated proposed rule identifying its remedy to reimburse hospitals unpaid by its unlawful 340B drug payment policy (the Proposed Rule). While the Supreme Court found CMS’s 340B...more

CMS Issues Transmittal Waiving Cap on Prior Year Payments for Nursing and Allied Health Education for Medicare Advantage Enrollees

On March 16, 2023, CMS issued Transmittal 11904, directing its contractors to adjust hospitals’ nursing and allied health education (NAH) payments associated with services furnished to Medicare Advantage (MA) enrollees. ...more

CMS Proposes Changes to Medicaid DSH Third-Party Payer Rule

On February 24, 2023, CMS issued a proposed rule updating its Medicaid Disproportionate Share Hospital (DSH) program regulations as a result of legislative changes made by the Consolidated Appropriations Act (CAA) of 2021....more

CMS Issues IPPS and LTCH Proposed Rule for FY 2023

On April 18, 2022, CMS issued its annual Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System Proposed Rule for FY 2023 (the Proposed Rule). In the Proposed Rule,...more

New Kidney Transplant Allocation Policy Survives Eighth Circuit Legal Challenge

On November 8, 2021, the Eighth Circuit affirmed a district court order that denied an attempt to preliminarily block the Organ Procurement and Transplant Network’s (OPTN) policy changing the manner in which donor kidneys are...more

CMS Extends CJR Model for Another Three Performance Years with Changes

On April 29, 2021, CMS issued a final rule extending the Comprehensive Care for Joint Replacement (CJR) bundled-payment model for an additional three performance years (the Final Rule). Originally slated to end September 30,...more

Court of Appeals Reverses Hospitals’ Victory in 340B Drug Reimbursement Case

On July 31, 2020, the U.S. Court of Appeals for the District of Columbia Circuit reversed a district court decision that had found unlawful Medicare’s nearly 30 percent rate cut for separately payable outpatient drugs...more

CMS Issues New Round of Waivers and Rule Changes In Response to COVID-19

Last week CMS issued a new round of regulatory waivers and rule changes in response to the COVID-19 public health emergency, including its Interim Final Rule with comment period, CMS-5531-IFC. The key changes relax certain...more

Hospitals Ask Appeals Court to Affirm Their Victory in Off-Campus Provider-Based Department Rate Cut Saga

On Thursday, February 20, 2020, hospitals represented by King & Spalding that operate excepted off-campus provided-based outpatient departments (PBDs) filed their brief in federal appeals court to preserve the victory they...more

CMS Issues Final Rule Aimed to Reduce Burden on Providers and Suppliers Through Regulatory Reforms

On September 26, 2019, CMS issued a Final Rule that CMS intends will reform certain Medicare regulations related to standards and certifications that CMS identified as “unnecessary, obsolete, or excessively burdensome.” CMS...more

CMS Publishes Proposed Rule for CY 2020 Hospital Outpatient Prospective Payment System, Includes Major Proposals on Price...

On July 29, 2019, CMS published a proposed rule revising the factors for determining Medicare payment rates under the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgery Center (ASC) Payment...more

Hospitals Criticize Senate Committee Revised “Benchmark Payments” Approach as Fix to End Surprise Billing

On June 19, 2019, the Senate Committee on Health, Education, Labor and Pensions (HELP), in the latest effort to curb “surprise billing,” released the “discussion draft” of its proposed “surprise billing” legislation. The...more

CMS Releases FY 2020 Medicare IPPS and LTCH PPS Proposed Rule and Proposes Key Changes to Several Regulatory Requirements

On April 23, 2019, CMS issued its annual Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System Proposed Rule for FY 2020 (the Proposed Rule), which will affect...more

Hospitals Challenge CMS’s Site-Neutral Payment Policies for Excepted Off-Campus Provider-Based Departments

On January 18, 2019, a group of nearly 40 hospitals filed a lawsuit in the United States District Court for the District of Columbia challenging CMS’s rate cut to evaluation and management (E/M) services furnished by excepted...more

New Hampshire Hospital Association v. Azar is Another Win for Hospitals in Medicaid DSH Reimbursement Litigation

On August 25, 2018, the U.S. District Court for the District of New Hampshire in New Hampshire Hospital Association v. Azar gavehospitals another victory in their claims that CMS unlawfully reduces Medicaid Disproportionate...more

D.C. District Court Sides with Secretary’s FY 2005 IPPS Final Rule Regarding DSH Calculation of Dual-Eligible Exhausted Days

On June 29, 2018, the U.S. District Court for the District of Columbia decided Stringfellow Memorial Hospital et al. v. Azar by granting summary judgment to the Secretary of HHS in his defense of the FY 2005 Inpatient...more

New Georgia Law Promotes Micro-Hospitals, Though CMS’s “Primarily Engaged” Standard Looms

On May 2, 2018, Georgia Governor Nathan Deal signed into law a bill allowing failed rural hospitals to be converted into “micro-hospitals.” The law comes as a response to a recent string of rural hospital closures and a...more

Trump Administration Proposes Expanding Short-term, Limited-duration Insurance Plans: A Potential Increase in Bad Debts for...

On February 20, 2018, the Trump administration announced a proposed rule to allow insurers to offer short-term, limited-duration insurance plans that provide coverage for a period of up to twelve months. The limit for this...more

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