In this episode, Andrew Ruskin, Leah Richardson, and Victoria Hamscho analyze the U.S. Court of Appeals for the Fourth Circuit’s recent decision in Genesis Healthcare v. Becerra. They discuss its potential impact on the...more
On 1 July 2021, the Department of Health and Human Services (HHS) opened the Provider Relief Fund Reporting Portal for funding recipients to start submitting information in accordance with the Post-Payment Notice of Reporting...more
On Friday, 11 June, the Department of Health and Human Services (HHS) released long-awaited updates to its reporting requirements for recipients of Provider Relief Fund (PRF) payments. HHS’s updated Post-Payment Notice of...more
How far can an agency go to allow agency-developed policy objectives to supersede concerns about faithful adherence to the law? Similarly, how much should health systems and others regulated by Medicare be concerned about...more
On November 20, the Centers for Medicare & Medicaid Services (CMS) issued the Most Favored Nation (MFN) Model interim final rule (MFN Rule), implementing President Trump’s proposal to align drug prices in the United States...more
In this episode of Triage, Andrew Ruskin and Victoria Hamscho provide an update on recent developments in the 340B Program and, in particular, on two recent legal challenges covered entities brought in response to drug...more
12/3/2020
/ Covered Entities ,
Dispute Resolution ,
Drug Pricing ,
Health Care Providers ,
HRSA ,
Manufacturers ,
Medicaid ,
OMB ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Section 340B
In this episode, Rebecca Schaefer and Victoria Hamscho provide an update on next month’s Supreme Court oral arguments in California v. Texas, a case in which the Court will be reviewing the constitutionality of key parts of...more
10/29/2020
/ Affordable Care Act ,
California v Texas ,
Constitutional Challenges ,
Health Care Providers ,
Health Insurance ,
Healthcare Reform ,
Individual Mandate ,
Oral Argument ,
Presidential Elections ,
Repeal ,
Tax Penalties
In recent weeks, several drug manufacturers have taken actions that impact covered entities participating in the 340B Drug Pricing Program (340B Program) and their contract pharmacies....more
In this episode, Richard Church, Andrew Ruskin, and Victoria Hamscho discuss recent developments in the 340B Drug Pricing Program, including recent actions by drug manufacturers to limit contract pharmacy access to 340B...more
7/23/2020
/ Covered Entities ,
Drug Pricing ,
Eli Lilly ,
Eligibility ,
Health Care Providers ,
Hospitals ,
HRSA ,
Merck ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Proposed Legislation ,
Reporting Requirements ,
Section 340B
In this episode, Richard Church and Victoria Hamscho discuss recent developments in the 340B Drug Pricing Program, including recent COVID-19 guidance by the Health Resources and Services Administration and hospital requests...more
4/9/2020
/ Coronavirus/COVID-19 ,
Covered Entities ,
Department of Health and Human Services (HHS) ,
Drug Pricing ,
DSH ,
DSH Adjustments ,
Eligibility Determination ,
Emergency Response ,
Group Purchasing Organizations (GPO) ,
Health Care Providers ,
Hospitals ,
HRSA ,
Medicaid ,
Medical Records ,
Medicare ,
Pharmaceutical Industry ,
Prescription Drugs ,
Section 340B ,
Social Security ,
Telehealth
On February 7, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued a notice relating to the agency’s intention to survey hospitals about their acquisition costs for specified covered outpatient drugs (“SCODs”)...more
In this episode, Macy Flinchum and Victoria Hamscho discuss recent developments in the 340B Drug Pricing Program, including recent guidance by the Centers for Medicare and Medicaid Services on best practices for states to...more
1/30/2020
/ Best Practices ,
Centers for Medicare & Medicaid Services (CMS) ,
Covered Entities ,
Discounts ,
Drug Pricing ,
Fee-for-Service ,
Health Care Providers ,
MCOs ,
Medicaid ,
Medicaid Drug Rebate Program ,
New Guidance ,
Pharmaceutical Industry ,
Prescription Drugs ,
Section 340B
In this episode, Ryan Severson and Victoria Hamscho discuss recent developments in pharmaceutical pricing and the 340B Drug Pricing Program heading into 2020, including reimbursement cuts for 340B drugs under the Outpatient...more
12/20/2019
/ Centers for Medicare & Medicaid Services (CMS) ,
Drug Pricing ,
Executive Orders ,
Final Rules ,
Health Care Providers ,
Hospitals ,
Legislative Agendas ,
Medicaid ,
Medicare ,
Outpatient Prospective Payment System (OPPS) ,
Pharmaceutical Industry ,
Pharmacies ,
Pharmacy Benefit Manager (PBM) ,
Physicians ,
Prescription Drugs ,
Proposed Legislation ,
Reimbursements ,
Section 340B