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340B Rebate Pilot Program Proposed by HRSA

On July 31, 2025, the Health Resources and Services Administration (HRSA), Office of Pharmacy Affairs (OPA) issued a 340B Drug Pricing Program notice (the “Notice”) announcing the launch of a voluntary 340B rebate model pilot...more

Telehealth Issues to Watch in 2023

During the COVID-19 pandemic, telehealth utilization exploded. Globally, the telehealth market is valued at $83.5 billion and is expected to grow by 24% between 2023 and 2030. As services delivered via telehealth became more...more

Pharma Manufacturer Federal Government Price Reporting: Recent Litigation and Settlements

​​​​​​​Litigation involving drug price reporting under the Medicaid Drug Rebate Program (MDRP)  has been very active in 2022. Most recently, on August 3, 2022, an Illinois federal jury levied a $61 million verdict against Eli...more

CMS Continues to Modernize by Expanding Reimbursement for Digital Health Services

The COVID-19 Public Health Emergency (“PHE”) fundamentally changed the healthcare industry, forcing healthcare providers and patients onto their computers and phones to enable continuation of care when patients were mandated...more

Heating Up: Federal Sunshine Act Enforcement on the Rise

After several years without any enforcement, the U.S. Department of Justice (“DOJ”) recently penalized medical device and life sciences companies for violating the U.S. Provider Payments Sunshine Act (“Sunshine Act”) (42...more

OIG Advocates for Increased Oversight of Medicaid Telehealth Services in Behavioral Health

Telehealth’s exponential growth –in part due to the COVID-19 pandemic – has highlighted both its value in increasing access to care and the potential for misuse. The U.S. Department of Health and Human Services’ Office of...more

CMS Proposes Important New Updates to the Sunshine Act’s Open Payments Program

The Centers for Medicare & Medicaid Services (CMS) released its proposed 2022 Physician Fee Schedule rule (Proposed Rule) on July 13, 2021. Included in the rule are several proposed updates to the CMS Open Payments Program,...more

Now May Be the Time for Ambulatory Surgery Centers to Enroll in the Hospitals Without Walls Program

The U.S. Department of Health & Human Services, Centers for Medicare and Medicaid Services’ Hospitals Without Walls Program (the “Program”) may be more crucial to helping hospitals handle the latest surge in COVID-19 cases...more

CMS Expands Availability Of Advances On Medicare Reimbursement; U.S. Cares Act Increases Medicare Reimbursement Rates

In response to the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) announced on Saturday March 28, 2020, that it is expanding its Medicare Accelerated and Advance Payment Program (AAPP) to...more

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