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Medicare Centers for Medicare & Medicaid Services (CMS) Regulatory Requirements

Arnall Golden Gregory LLP

When Patients Leave Against Medical Advice: What Hospitals Miss and Why It Matters

Delivering high-quality healthcare becomes difficult when patients disregard their doctors’ advice. A patient who chooses to leave the hospital against medical advice (“AMA”) represents a particularly severe case of...more

Gardner Law

NTAP: How to Secure Supplemental Medicare Reimbursement in FY2027

Gardner Law on

The New Technology Add-On Payment (NTAP) program remains one of the most powerful and underutilized tools for securing Medicare reimbursement for novel medical technologies. For eligible products, NTAP provides additional...more

Gardner Law

TCET—A Medicare Coverage Option for Breakthrough Devices

Gardner Law on

For many device makers, the biggest commercial hurdle isn’t FDA authorization—it’s the long wait for Medicare to decide on coverage. Historically, the gap between FDA market authorization and a National Coverage Determination...more

Alston & Bird

Health Care Week in Review | CMS Announces Oversight Initiative to Increase Medicaid and CHIP Citizenship Enforcement; HHS...

Alston & Bird on

Below is Alston & Bird’s Health Care Week in Review, which provides a synopsis of the latest news in health care regulations, notices, and guidance; federal legislation and congressional committee action; reports, studies,...more

McGuireWoods LLP

CMS Proposes Reimbursement Changes for Remote Patient Monitoring

McGuireWoods LLP on

On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule (PFS Proposed Rule). The PFS Proposed Rule proposes to reduce requirements for several...more

King & Spalding

CMS Issues FY 2026 Inpatient Rehabilitation Facility Prospective Payment System and Quality Reporting Program Final Rule

King & Spalding on

On August 1, 2025, CMS issued a final rule updating the Medicare rates and policies applicable to inpatient rehabilitation facilities (IRFs) under the IRF Prospective Payment System (PPS) and the IRF Quality Reporting Program...more

Foley & Lardner LLP

CY 2026 Medicare PFS Proposed Rule: Telehealth Takeaways

Foley & Lardner LLP on

In July 2025, the Centers for Medicare & Medicaid Services (CMS) released the CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule (the Proposed Rule), which included several proposed changes that aim to expand...more

Paul Hastings LLP

CMS Proposes Major ASP Reporting Overhaul — Implications for Fair Market Value and Bona Fide Service Fees

Paul Hastings LLP on

The Centers for Medicare & Medicaid Services (CMS) recently published its Proposed 2026 Physician Fee Schedule Rule (Proposed Rule), with extensive implications for drug pricing, Average Sales Price (ASP) calculations, and...more

Pullman & Comley - Connecticut Health Law

New Billing Codes for At-Home Acute Kidney Injury Renal Dialysis

Earlier this year, the Centers for Medicare and Medicaid Services (CMS) confirmed that, effective January 1, 2025, CMS will pay for acute kidney injury (AKI) renal dialysis treatments at-home at the daily rate based on...more

Jones Day

Coming January 2026: CMS Launches AI Program to Screen Prior Authorization Requests for Treatments

Jones Day on

New CMS program, WISeR, will leverage third parties to screen prior authorization requests using technologically enhanced processes....more

Orrick, Herrington & Sutcliffe LLP

Opportunities and Risks in Remote Patient Monitoring and Remote Therapeutic Monitoring for 2026

The Calendar Year 2026 Medicare Physician Fee Schedule (PFS) proposed rule (see Orrick’s analysis of the proposed rule here) contains important signals for the future of remote patient monitoring (RPM) and remote therapeutic...more

Foley & Lardner LLP

Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM): What You Need to Know About CMS’ Proposed Changes

Foley & Lardner LLP on

On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) proposed key changes to remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) services reimbursed under the Medicare program. The...more

Mintz - Health Care Viewpoints

CMS Proposes New Standards for Bona Fide Service Fees in Average Sales Price Calculations: What Plans, PBMs, and Other Recipients...

The CY 2026 Physician Fee Schedule Proposed Rule (PFS Proposed Rule) introduces significant changes to how drug manufacturers must treat Bona Fide Service Fees (BFSFs) when calculating Average Sales Price (ASP) for Medicare...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

Ropes & Gray LLP

Proposed Changes to Medicare Payment Rules: What Life Sciences Companies Need to Know

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The Centers for Medicare & Medicaid Services (“CMS”) recently released two proposed updates to Medicare payment rules that, if implemented, could have a significant impact on life sciences companies. The Medicare proposed...more

Mintz - Health Care Viewpoints

WISeR Model Will Test the Use of Artificial Intelligence for Prior Authorization in Medicare: Key Considerations for Health Care...

The Center for Medicare and Medicaid Innovation (CMMI) recently announced a six-year payment model for 2026-2031 called the Wasteful and Inappropriate Service Reduction (WISeR) Model. WISeR will test the use of artificial...more

Foley & Lardner LLP

Update: CMS Extends Skilled Nursing Facilities’ Medicare Revalidation Deadline

Foley & Lardner LLP on

On July 17, 2025, the Centers for Medicare and Medicaid Services (CMS) announced an additional extension of the deadline by which skilled nursing facilities (SNFs) must revalidate their Medicare enrollments. Enrolled SNFs...more

McDermott+

Site neutrality is on the menu in the CY 2026 Medicare Outpatient Prospective Payment System proposed rule

McDermott+ on

Last week, the Centers for Medicare & Medicaid Services (CMS) issued two major regs: the calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule and the CY 2026 Outpatient Prospective Payment System (OPPS)...more

Arnall Golden Gregory LLP

SNF Off-Cycle CMS-855A Reporting Delayed to January 1, 2026

The Centers for Medicare & Medicaid Services (“CMS”) has extended the window for skilled nursing facilities (“SNFs”) to file off-cycle Medicare revalidation documents until January 1, 2026. This marks CMS’ third deadline...more

WilmerHale

2024 CMS Audit and Enforcement Report

WilmerHale on

On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released an Audit and Enforcement Report summarizing its annual Medicare Advantage (Part C) and Prescription Drug (Part D) program audits and enforcement...more

Hogan Lovells

Medicare proposed rules include government pricing surprises: ASP changes and maximum fair price, new bona fide service fee and...

Hogan Lovells on

Every July, the Centers for Medicare & Medicaid Services (CMS) publishes two proposed rules relating to how it plans to administer the Medicare Part B program for the next calendar year: the physician fee schedule (PFS)...more

Benesch

Off-Cycle Medicare Revalidations for SNFs – Deadline Extended Again to January 1, 2026

Benesch on

On July 17, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced via a Medicare Learning Network (“MLN”) update that the deadline for submission of mandatory off-cycle Medicare revalidations...more

DLA Piper

Proposed CY 2026 Medicare Physician Fee Schedule: Key Changes Impacting the Medicare Shared Savings Program

DLA Piper on

On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) released the 2026 calendar year (CY 2026) Medicare Physician Fee Schedule (Proposed Rule). Among the many changes proposed, the Proposed Rule includes...more

McDermott+

CMS releases CY 2026 Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System proposed rule

McDermott+ on

On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule [CMS-1834-P],...more

Benesch

CMS’s CY 2026 Fee Schedule Proposal: MSSP Reforms Take Center Stage in Push Toward Value

Benesch on

On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the proposed rule for the Calendar Year (“CY”) 2026 Medicare Physician Fee Schedule (“PFS”), formally titled CMS-1832-P....more

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