News & Analysis as of

Hospitals Comment Period

Holland & Knight LLP

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

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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

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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

Sheppard Mullin Richter & Hampton LLP

CMS Proposes Medicare Payment Policies for Hospital Inpatient Services for Federal Fiscal Year 2026

The Centers for Medicare & Medicaid Services (CMS) recently published the fiscal year (“FY”) 2026 proposed rule for Hospital Inpatient Prospective Payment Systems (IPPS) (the “Proposed Rule”). Comments to the Proposed Rule...more

Holland & Knight LLP

CMS Releases Fiscal Year 2026 IPPS and LTCH Proposed Rule

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The Centers for Medicare & Medicaid Services (CMS) on April 11, 2025, issued the proposed fiscal year (FY) 2026 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Acute Care Hospital (LTCH) Rule...more

Holland & Knight LLP

CMS Releases CY 2025 OPPS and ASC Proposed Rule

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The Centers for Medicare & Medicaid Services (CMS) has released the calendar year (CY) 2025 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS-1809-P),...more

Mayer Brown

Private Equity in Healthcare: Increased Scrutiny from FTC, DOJ, and HHS

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Private equity acquisitions in healthcare will likely face increased scrutiny from multiple federal departments, as well as from state antitrust enforcement officials....more

Holland & Knight LLP

Holland & Knight Health Dose: February 6, 2024

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Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector....more

Holland & Knight LLP

CMS Releases CY 2024 OPPS and ASC Proposed Rule

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The Centers for Medicare & Medicaid Services (CMS) has released the calendar year (CY) 2024 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS-1786-P),...more

McDermott Will & Emery

Remote Monitoring: CMS Clarifies Guidance, Proposes Rural Provider Payment, Requests Information on Digital Therapeutics

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Over the past several years, the Centers for Medicare and Medicaid Services (CMS) has expanded payment for care management and remote monitoring services in an effort to recognize and pay for non-face-to-face services that...more

Nelson Mullins Riley & Scarborough LLP

Hospital Price Transparency Changes in the Calendar Year 2024 Hospital Outpatient Prospective Payment System Proposed Rule

As part of the Calendar Year 2024 Outpatient Prospective Payment System and Ambulatory Surgical Center Proposed Rule issued on July 13, 2023, the Centers for Medicare and Medicaid Services (CMS) proposed changes to the...more

Bricker Graydon LLP

340B Update: Proposed Rule on Drug Acquisition Cost Cuts Suggests Lump Sum Repayment

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The Department of Health and Human Services has published a proposed rule to address short payments on drug acquisition costs for 340B hospitals from 2018 to September 2022. On June 15, 2022, the Supreme Court unanimously...more

McDermott Will & Emery

CMS Releases Proposed Remedy for 340B-Acquired Drugs Purchased in CYs 2018–2022

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On July 7, 2023, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule, Hospital Outpatient Prospective Payment System: Remedy for 340B-Acquired Drugs Purchased for Calendar Years 2018–2022, to...more

BakerHostetler

FDA Clarifies Prohibition on Wholesaling Under Section 503B of the Federal Food, Drug, and Cosmetic Act

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On June 27, 2023 the FDA published Prohibition on Wholesaling Under Section 503B of the Federal Food, Drug, and Cosmetic Act; Draft Guidance for Industry. In this draft guidance, FDA provides examples of activities prohibited...more

Dorsey & Whitney LLP

New Minnesota Health Care Transaction Oversight Law Imposes Additional Requirements on Nonprofit Health Care Entities

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On May 26, 2023, the Governor of Minnesota signed into law Minnesota bill HF 402 to increase government oversight of health care transactions that occur in Minnesota or involve Minnesota-based health care entities....more

Holland & Knight LLP

UPDATE: Proposed New York "Material Transaction" Review Law Scaled Back

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In a prior blog post, we summarized proposed legislation that would have conferred upon the New York State Department of Health (DOH) the authority to review and approve "material transactions" involving a "health care...more

Holland & Knight LLP

CMS Proposes FY 2024 Inpatient Payment Policies for Hospitals

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The Centers for Medicare & Medicaid Services (CMS or Agency) on April 10, 2023, published its annual proposed rule for the federal fiscal year (FY) 2024 Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital...more

McDermott Will & Emery

Proposed Changes to DSH Payment Calculation Regulations Could Impact 340B Hospitals

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On February 28, 2023, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule that would change how Medicare disproportionate share hospital (DSH) payments are calculated with respect to the counting of...more

McDermott Will & Emery

California DxF Policies and Procedures Released for Public Comment

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On January 17, 2023, the California Health and Human Services Agency (CalHHS) released updated drafts of four policies and procedures (P&Ps) under the California Data Exchange Framework (DxF) to support the implementation of...more

Bass, Berry & Sims PLC

CMS Proposes New Stark Law Exception for Rural Emergency Hospitals

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On July 15, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System proposed rule...more

Holland & Knight LLP

CMS Releases CY 2023 Outpatient and ASC Payment System Proposed Rule

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The Centers for Medicare & Medicaid Services (CMS) has released the calendar year (CY) 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS-1772-P),...more

McDermott Will & Emery

CMS Seeks to Establish Regulations Limiting Critical Access Hospital Location Requirement

Tucked into the recent proposed rule establishing Rural Emergency Hospital Conditions of Participation (CoPs) is a proposal to change the CoPs for critical access hospitals (CAHs). The Centers for Medicare & Medicaid Services...more

McDermott Will & Emery

One Step Closer to a New Provider Type: CMS Issues Proposed Rule on Rural Emergency Hospital Conditions of Participation

On June 30, 2022, the Centers for Medicare & Medicaid Services (CMS) released the long-awaited proposed rule establishing the Conditions of Participation (CoPs) that Rural Emergency Hospitals (REHs) would be required to meet...more

Holland & Knight LLP

CMS Finalizes Policies on Residency Positions and Organ Procurement Payment

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The Centers for Medicare & Medicaid Services (CMS) has released the Final Rule with a comment period for the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals; Changes to Medicare Graduate Medical...more

Bowditch & Dewey

New CMS Regulations Mandating Vaccination of Health Care Facility Staff

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On November 5, 2021, the Centers for Medicare & Medicaid Services (“CMS”) issued an interim final rule requiring that a wide variety of providers and suppliers participating in the Medicare program ensure their staff are...more

Holland & Knight LLP

Healthcare Law Update: October 2021

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Kathryn Isted In Harbor Healthcare System, L.P. v. United States, 5 F.4th 593 (5th Cir. 2021), the court of appeals ruled that the district court abused its discretion in refusing to exercise its equitable jurisdiction over a...more

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