News & Analysis as of

Comment Period Centers for Medicare & Medicaid Services (CMS) Reporting Requirements

Husch Blackwell LLP

HHS Unveils 340B Drug Rebate Pilot Program

Husch Blackwell LLP on

On July 31, 2025, the U.S. Department of Health and Human Services (HHS) announced that it will conduct a pilot program testing out a rebate model for 340B drug purchases. Under the program, drug manufacturers will be allowed...more

Goodwin

340B Rebate Pilot Program Proposed by HRSA

Goodwin on

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

Tucker Arensberg, P.C.

CMS Unveils 2026 Physician Fee Schedule Proposal: Key Changes Ahead

Tucker Arensberg, P.C. on

On July 14, the Centers for Medicare & Medicaid Services (CMS) released its proposed rule for the 2026 Physician Fee Schedule. As expected, there are several meaningful updates that providers, practices, and health systems...more

Holland & Knight LLP

CMS Releases CY 2026 Outpatient Prospective, ASC Payment System Proposed Rule

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) on July 15, 2025, issued the Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems proposed rule, which proposes updates to the...more

Polsinelli

CMS Issues Request for Public Input on Hospital Pricing Transparency

Polsinelli on

Key Takeaways - 1. Centers for Medicare & Medicaid Services (CMS) Aims to Strengthen Enforcement - The agency is evaluating how to better enforce hospital price transparency rules under the Executive Order....more

Latham & Watkins LLP

CMS Seeks Healthcare Industry Input on Future of Digital Health

Latham & Watkins LLP on

Comments on the RFI, due by June 16, present a rare opportunity to shape future technology standards, reporting requirements, and business opportunities....more

WilmerHale

Proposed Changes to CMS Regulations May Impact False Claims Act Liability for Medicare Overpayments

WilmerHale on

The Centers for Medicare & Medicaid Services (CMS) proposed a rule late last year that would impose standards on healthcare providers and suppliers to report and return overpayments from Medicare that mirror aspects of the...more

Jackson Walker

CMS Implements Stricter COVID-19 Testing Regulations on Nursing Homes

Jackson Walker on

As part of a broader Trump administration announcement made on August 25, 2020, the Centers for Medicare & Medicaid Services (CMS) issued sweeping oversight changes in the form of an Interim Final Rule with Comment Period...more

Akin Gump Strauss Hauer & Feld LLP

CMS Proposes New Hospital Reporting Requirements and Signals Major Shift in Hospital Rate-Setting Methods

- Tucked into a massive Medicare payment rule is a proposal to fundamentally change how CMS sets hospital payment rates. - Recognizing that a hospital’s chargemaster rarely reflects true market costs, CMS seeks to use...more

ArentFox Schiff

CMS Releases Proposed Changes for Medicare Advantage and Medicare Part D

ArentFox Schiff on

The Centers for Medicare & Medicaid Services (CMS) published the Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program,...more

Holland & Knight LLP

Comments on CMS Proposed Rule on Medicaid Fiscal Accountability Due Feb. 1, 2020

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) on Nov. 18, 2019, published a proposed Medicaid Fiscal Accountability rule that would amend existing regulations related to 1) base and supplemental payments, 2)...more

King & Spalding

CMS Issues Proposed Rule Aimed at Increasing Transparency and Reducing Medicaid Program Spending

King & Spalding on

On November 18, 2019, CMS published the proposed Medicaid Fiscal Accountability Rule (the Proposed Rule) which, if finalized, would result in dramatic changes to the Medicaid program. Through the Proposed Rule, CMS aims to...more

McDermott Will & Schulte

CMS Final Rule Strengthens Integrity of Medicare Provider Enrollment Process

On September 10, 2019, the US Department of Health and Human Services Centers for Medicare & Medicaid Services (CMS) published a final rule (Final Rule) expanding Medicare, Medicaid and Children’s Health Insurance Program...more

ArentFox Schiff

Guilt by Affiliation: New CMS Regulations Require Provider Disclosure of Past Association with “Bad Actors”

ArentFox Schiff on

On September 10, 2019, the Centers for Medicare and Medicaid Services (CMS) issued a final rule with comment period, titled Program Integrity Enhancements to the Provider Enrollment Process (the “Final Rule”), which enhances...more

Bass, Berry & Sims PLC

Providers and Suppliers: Do You Have Skeletons in Your Enrollment Closet?

Bass, Berry & Sims PLC on

On September 10, 2019, the Centers for Medicare & Medicaid Services (CMS) published a final rule significantly expanding its authority to deny or revoke participation in Medicare, Medicaid or the Children’s Health Insurance...more

McGuireWoods LLP

CMS Proposes Revising Physician Payments Sunshine Act Reporting Requirements

McGuireWoods LLP on

On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the Medicare CY 2020 Physician Fee Schedule proposed rule (the Proposed Rule), including proposed changes to regulations implementing the...more

Akin Gump Strauss Hauer & Feld LLP

CMS Issues Proposed Revisions to Open Payments/Sunshine Act Reporting Requirements

• On July 29, 2019, CMS released its proposed 2020 Physician Fee Schedule rule, which includes the much anticipated proposed regulatory changes to the Sunshine Act/Open Payments program (“Open Payments”). The proposed...more

Cooley LLP

Blog: Proposed Rule Issued by CMS re: Expansion of Open Payments Reporting

Cooley LLP on

The Centers for Medicare & Medicaid Services (CMS) issued this week a proposed rule regarding the expansion of Open Payments reporting requirements (Proposed Rule). ...more

Baker Donelson

CMS Seeks Additional Ideas for Reducing Administrative Burdens in Health Care

Baker Donelson on

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) focused once again on reducing the administrative burden for physicians by reviewing and revising regulations. The RFI, published...more

Holland & Knight LLP

CMS Issues Proposed Rule on Medicare Physician Payment in 2019

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) on July 12, 2018, published the CY 2019 Proposed Rule for the Medicare Physician Fee Schedule (PFS). While in previous years regulations for the Quality Payment Program (QPP)...more

Holland & Knight LLP

CMS Proposed Rule CMS-1694-P — Hospital Pricing and Electronic Medical Records: Increasing Patient Access

Holland & Knight LLP on

On April 24, 2018, the Centers for Medicare and Medicaid Services (CMS) issued for comment a 1883-page proposed rule (CMS-1694-P) (the "Proposed Rule") that aims, among other goals, to increase transparency relating to...more

Mintz - Health Care Viewpoints

CMS Releases the Final Medicare Part D DIR Reporting Requirements for 2016

On Friday, June 23, 2017, CMS released the Final Medicare Part D DIR Reporting Requirements for 2016. Part D sponsors may begin submitting their DIR information on June 30, 2017 and must finish their submissions by the end of...more

Mintz - Health Care Viewpoints

CMS Releases the Proposed Part D DIR Reporting Requirements for 2016

Yesterday, CMS released the Proposed Part D DIR (Direct and Indirect Remuneration) Reporting Requirements for 2016 and postponed the 2016 DIR Reporting deadline....more

Polsinelli

CMS Proposes OPPS Reimbursement Adjustments: What Hospital Outpatient Providers Need to Know

Polsinelli on

In early July, the Centers for Medicare & Medicaid Services (CMS) proposed Hospital Outpatient Prospective Payment System (OPPS) reimbursement rule changes that will impact reimbursement payment amounts and requirements for...more

Foley Hoag LLP

Summary: PAMA Final Rule

Foley Hoag LLP on

Market Based Payment for Clinical Diagnostic Laboratory Tests - Summary - On June 17, 2016 the Centers of Medicare & Medicaid Services (CMS) issued the long awaited Medicare Clinical Diagnostic Laboratory Tests...more

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