Samuel Dennis Mkrtchian on Centers for Medicare & Medicaid Services (CMS)

Senate Finance Committee Releases Budget Bill with More Aggressive Medicaid Provider Changes Than House Version

On June 16, 2025, the U.S. Senate Finance Committee released draft legislative language for its version of the “One Big Beautiful Bill Act,” a comprehensive budget reconciliation proposal that includes significant changes to...more

7/3/2025 / Centers for Medicare & Medicaid Services (CMS) , Federal Funding , Healthcare Facilities , Healthcare Reform , Medicaid , Proposed Legislation , Proposed Regulation , Senate Finance Committee , State and Local Government

House Passes Reconciliation Bill Impacting Medicaid Financing, Programs, and Eligibility

On May 22, 2025, the House passed H.R. 1, the One Big Beautiful Bill Act (the Bill), its budget reconciliation legislation that upheld most of the Medicaid-related provisions originally approved by the House Energy and...more

6/6/2025 / Budget Reconciliation , Centers for Medicare & Medicaid Services (CMS) , Federal Funding , Government Agencies , Health Insurance , Healthcare , Healthcare Reform , Medicaid , New Legislation , Proposed Legislation , State and Local Government

Budget Reconciliation Bill Impacts Medicaid Financing, Programs, and Eligibility

Last week, the House Energy & Commerce Committee marked up legislation that would significantly affect the Medicaid program, including changes to state Medicaid financing mechanisms, state directed payment programs that...more

6/3/2025 / Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Healthcare Reform , Hospitals , Medicaid , New Legislation , Proposed Legislation , State and Local Government , State Budgets

Physician Fee Schedule Proposed Rule Proposes New Quality-Driven Payment Policies

Within its proposed CY 2025 Physician Fee Schedule (PFS) rule (the Proposed Rule), CMS is proposing to implement new payment policies intended to advance health equity and support whole-person care. CMS expects these new...more

7/23/2024 / ACOs , Centers for Medicare & Medicaid Services (CMS) , Food and Drug Administration (FDA) , Health Care Providers , Medicaid , Medicare Shared Savings Program , MIPS , Payment Systems , Physician Fee Schedule , Proposed Rules , Telehealth

Florida Magistrate Judge Rules Against Florida’s Efforts to Prohibit CMS from Enforcing an Informational Bulletin on Health...

On January 29, 2023, a Florida Magistrate Judge recommended denying the State of Florida’s Motion for Preliminary Injunction and granting CMS’s Motion to Dismiss in connection with the implementation and enforcement of its...more

2/7/2024 / Advanced Payment Program , Centers for Medicare & Medicaid Services (CMS) , Class Action , Financing , Florida , Health Care Providers , Healthcare Reform , Jurisdiction , Motion to Dismiss , Preliminary Injunctions , State and Local Government , State Medicaid Programs

CMS Issues Proposed Rule on Minimum Staffing Requirements for Long-Term Care Facilities

On September 1, 2023, CMS issued the Minimum Staffing Standards for Long-Term Care (LTC) Facilities and Medicaid Institutional Payment Transparency Reporting proposed rule (the Proposed Rule), which imposes nurse staffing...more

9/14/2023 / Centers for Medicare & Medicaid Services (CMS) , Civil Monetary Penalty , Long Term Care Facilities , Medicaid , Medicare , Proposed Rules

CMS Issues Initial Guidance for Medicare Drug Price Negotiation for 2026

On March 15, 2023, CMS released initial guidance detailing the requirements and parameters on key elements of the new Medicare Drug Price Negotiation Program for 2026, which is the first year that negotiated prices will apply...more

3/24/2023 / Centers for Medicare & Medicaid Services (CMS) , Drug Pricing , Inflation Reduction Act (IRA) , Medicare , Medicare Advantage , Medicare Part B , Medicare Part D , New Guidance

Group of Agency Inspectors General Publishes Report on Program Integrity Risks Across Certain Health Care Programs During the...

On December 1, 2022, the Pandemic Response Accountability Committee (PRAC) Health Care Subgroup published a report about the use of telehealth in selected health care programs across six federal agencies during the first year...more

12/8/2022 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Department of Defense (DOD) , Department of Health and Human Services (HHS) , Department of Justice (DOJ) , Healthcare , Medical Billing Codes , Medicare , OIG , Telehealth , TRICARE

CMS Issues CY 2023 Physician Fee Schedule Final Rule

Last week, CMS released the Calendar Year (CY) 2023 Physician Fee Schedule (PFS) final rule (the Final Rule). Under the Final Rule, CMS finalized a number of updates, revisions, and changes to Medicare payment policies for...more

11/17/2022 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Final Rules , Medical Evaluation Reports , Medicare , Mental Health , Physician Fee Schedule , Public Health Emergency , Telehealth

Accreditation Organizations are Required to Notify CMS of Change of Ownership Under Final Rule

On April 29, 2022, CMS published a final rule requiring Accreditation Organizations (AOs) to notify CMS of changes of ownership (CHOWs). Effective June 28, 2022, an AO will need to notify CMS when undergoing or negotiating a...more

5/5/2022 / Accreditation , Centers for Medicare & Medicaid Services (CMS) , Change of Ownership , Final Rules , Health Care Providers , Medicare , Suppliers

D.C. Circuit Rejects Critical Access Hospital’s Appeal for Medicare Payments to On-Call Specialty Physicians

On April 15, 2022, the D.C. Circuit affirmed the denial of a California hospital’s request to obtain critical access hospital cost reimbursement from Medicare for the costs incurred to keep non-emergency specialty physicians...more

4/25/2022 / Appeals , Centers for Medicare & Medicaid Services (CMS) , Critical Access Hospitals , Emergency Rooms , EMTALA , Medicare , Provider Payments , Reimbursements

D.C. District Court Upholds HHS’s Audits of Hospitals’ Worksheet S-10 and Resulting Adjustments When Determining Medicare DSH...

On August 30, 2021, the United States District Court for the District of Columbia ruled in favor of HHS and dismissed claims related to improper audits that resulted in adjustments to plaintiff hospitals’ Worksheet S-10 that...more

9/9/2021 / Administrative Procedure Act , Affordable Care Act , Audits , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Medicare , Medicare Act , Motion for Summary Judgment , Provider Reimbursement Review Board

CMS Issues Medicare IPPS and LTCH Final Rule for FY 2022

On August 2, 2021, CMS published the Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) final rule for federal fiscal year (FY) 2022. The final...more

8/10/2021 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Health Care Providers , Healthcare Facilities , Healthcare Workers , Hospitals , Inpatient Prospective Payment System (IPPS) , Long Term Care Facilities , Medicare , Medicare Advantage , Prospective Payment System (PPS) , Reporting Requirements , Vaccinations , Wage Index

Samuel Dennis Mkrtchian

King & Spalding

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