News & Analysis as of

Disclosure Requirements Health Care Providers Final Rules

McDermott+

Breaking Down the New No Surprises Act FAQs Post-TMA III

McDermott+ on

On January 14, 2025, the US Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments), along with the Office of Personnel Management (OPM), jointly issued Part 69 of a series of...more

Hendershot Cowart P.C.

Major Changes to Texas Medical Board Rules: What Healthcare Providers Need to Know

Hendershot Cowart P.C. on

On January 9, 2025, the Texas Medical Board (TMB) implemented comprehensive changes to its rules, marking a significant shift in how medical spas, IV hydration clinics, and other healthcare facilities operate in Texas....more

Harris Beach Murtha PLLC

"No Surprises Act" Ruling Favors Regulators, Insurers

Federal regulators recently won a large legal victory when the Fifth Circuit Court of Appeals upheld several provisions of the rule regulating Qualified Payment Amount (“QPA”) calculations under the No Surprises Act (the...more

Quarles & Brady LLP

Key Considerations for Healthcare Providers Responding to Law Enforcement Requests

Quarles & Brady LLP on

Why is everyone talking about provider disclosures to law enforcement of late? The Senate Finance Committee authored a letter to Xavier Becerra, Secretary of the U.S. Department of Health and Human Services (HHS), outlining...more

Davis Wright Tremaine LLP

Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

McDermott Will & Emery

Private Equity and REITs, Take Note! CMS Finalizes Nursing Facility Ownership Disclosure Requirements

McDermott Will & Emery on

On November 17, 2023, the US Department of Health and Human Services (HHS) published a final rule requiring nursing facilities participating in Medicaid and skilled nursing facilities participating in Medicare to disclose...more

Goodwin

Additional Disclosure Required: CMS Implements Substantial Changes to Reporting Skilled Nursing Facility Ownership Information

Goodwin on

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule that will require skilled nursing facilities (SNFs) to disclose an expanded array of ownership, managerial, and control information...more

Troutman Pepper Locke

After Multiple Strikes, Final Rules Issued for the No Surprises Act

Troutman Pepper Locke on

On August 19, the U.S. Departments of Health and Human Services, Labor, and the Treasury (the Departments) issued final rules implementing the No Surprises Act, known as the “Requirements Related to Surprise Billing: Final...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Goodwin

HHS, Labor, and Treasury Departments Defer Enforcement of Transparency in Coverage and No Surprises Act Requirements

Goodwin on

The No Surprises Act and Transparency in Coverage final rules go into effect January 1, 2022. Implemented as Titles I and II of Division BB of the Consolidated Appropriations Act, these rules are intended to protect patients...more

Mintz - Health Care Viewpoints

HHS Further Amends 42 CFR Part 2, Easing Some, But Not All, Burdens on Substance Use Disorder Treatment Providers

The U.S. Department of Health and Human Services (HHS) recently released a final rule further amending 42 CFR Part 2 regulations (Part 2) to allow greater sharing of patient records related to substance use disorder (SUD)...more

Jones Day

February 2, 2020 is Here: Are Your Agreements Compliant With the Part 2 Rule?

Jones Day on

The Situation: The two-year grace period for updating agreements of "lawful holders" (i.e., recipients named on patient consent forms obtained pursuant to the Part 2 Rule) with contractors, subcontractors, and legal...more

Baker Donelson

Medicare Revocation Consequences Worsened – Further Reenrollment Restrictions

Baker Donelson on

CMS recently finalized the most significant changes to enrollment since the 2006 enrollment rules were initially adopted. Overview of the New Rule - In its "Program Integrity Enhancements to the Provider Enrollment...more

King & Spalding

HHS Issues Final Rule Requiring Disclosure of Partial Refills of Prescriptions to Help Curb Opioid Abuse

King & Spalding on

On January 23, 2020, HHS issued its final rule adopting a modification of the requirements for the use of the Telecommunication Standard Implementation Guide, Version D.0, National Council for Prescription Drug Programs...more

Epstein Becker & Green

Despite Issuance of Final Rule on Price Transparency, Are Health Care Rates Too Complicated to Be “Consumer Friendly”?

Epstein Becker & Green on

The Centers for Medicare & Medicaid Services (“CMS”) recently issued a final rule requiring hospitals to publicly disclose their rates, including negotiated rates with third-party payors regardless of product line, by January...more

Ballard Spahr LLP

Health Care and Price Transparency: The Latest Summary

Ballard Spahr LLP on

Federal executive agencies recently published two rules, one final and one proposed, aimed at publicizing the various costs associated with health care. A final rule, promulgated by the Department of Health and Human Services...more

Bass, Berry & Sims PLC

CMS Finalizes Highly Anticipated Hospital Price Transparency Rule

Bass, Berry & Sims PLC on

On November 15, 2019, the Centers for Medicare & Medicaid Services (CMS) finalized a rule requiring hospitals to make public a list of standard charges for items and services provided by such hospitals (the Rule). (The...more

Dorsey & Whitney LLP

New Disclosure Requirements to be Phased-In to CMS Enrollment and Revalidation Process

Dorsey & Whitney LLP on

On September 5, 2019, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (“Final Rule”) effective November 4, 2019, which increases disclosure requirements for the provider and supplier enrollment and...more

Bass, Berry & Sims PLC

Trump Administration Proposes Transparency Rule for Group Health Plans and Insurers

Bass, Berry & Sims PLC on

On November 15, 2019, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the Departments), unveiled a proposed rule (scheduled to be published on November...more

Steptoe & Johnson PLLC

CMS’ Expanded Revocation Authority Threatens Health Care Providers’ Medicare Enrollment

Steptoe & Johnson PLLC on

On September 5, 2019, the Centers for Medicare & Medicaid Services (CMS) announced a final rule expanding CMS’ authority to deny or revoke enrollment in the Medicare program as a result of “bad actor” affiliations. Providers...more

McDermott Will & Emery

CMS Final Rule Strengthens Integrity of Medicare Provider Enrollment Process

McDermott Will & Emery on

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

Mintz - Health Care Viewpoints

Key Takeaways from CMS’s Final Rule Requiring the Disclosure of Affiliates during Provider Enrollment

The Centers for Medicare & Medicare Services (CMS) recently published a final rule with comment period (the “Final Rule”) that is designed to increase CMS’s ability to identify and prevent bad actors from participating in...more

Nelson Mullins Riley & Scarborough LLP

SAMHSA Final Rule Expands Permitted Disclosures of Substance Use Disorder Information to Subcontractors

The Substance Abuse and Mental Health Services Administration (SAMHSA) has issued a final rule (Rule) updating the Confidentiality of Substance Use Disorder Records, 42 CFR part 2 (Part 2), to expand the circumstances under...more

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