News & Analysis as of

Proposed Rules Healthcare

McDermott Will & Schulte

CMS proposes RPM reimbursement updates, requests information on reimbursing for SaaS

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

Polsinelli

Virtual Oversight, Real Impacts: “Incident-To” and Beyond in CMS’s CY 2026 PFS Proposed Rule

Polsinelli on

Key Takeaways - CMS proposes to significantly expand the use of virtual direct supervision for incident-to services, removing prior limitations based on Professional Component (PC)/Technical Component (TC) indicators and...more

Tucker Arensberg, P.C.

CMS Unveils 2026 Physician Fee Schedule Proposal: Key Changes Ahead

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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

McDermott+

Healthcare Preview for the Week of: July 28, 2025

McDermott+ on

Senate Steers Toward Summer Break - With the House already on August recess, the Senate will consider several of President Trump’s nominees, including Gustav Chiarello III to be an assistant secretary of the US Department of...more

Latham & Watkins LLP

Healthcare Life Sciences Drug Pricing Digest - July 2025 #2

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The Centers for Medicare & Medicaid Services (CMS) released the calendar year 2026 Physician Fee Schedule (PFS) proposed rule, which was published in the Federal Register on July 16, 2025. The comment period ends on September...more

McDermott Will & Schulte

Reducing hospital payments: CMS proposes expanded site-neutral payment policy for drug administration services

Consistent with recent attention from Congress and rhetoric from the Trump administration, the Calendar Year 2026 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule (the Proposed Rule) includes...more

King & Spalding

CMS Issues CY 2026 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed...

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On July 15, 2025, CMS issued a proposed rule with updates to the Medicare payment rates for the Hospital Outpatient Prospective Payment System (OPPS) and the Medicare Ambulatory Surgical Center (ASC) payment system for...more

Bass, Berry & Sims PLC

CMS Proposes Mandatory Two-Sided Risk Model for Specialists Treating Heart Failure and Low Back Pain

Bass, Berry & Sims PLC on

On July 16, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule for the Ambulatory Specialty Model (ASM), a mandatory, five-year alternative payment model for select specialists who regularly treat...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

Holland & Knight LLP

Holland & Knight Health Dose: July 22, 2025

Holland & Knight LLP on

With the One Big Beautiful Bill Act (OBBB) passed by U.S. Congress and signed into law, Congress now has less than three weeks that it will be in session before government funding expires on Sept. 30, 2025. Appropriators will...more

DLA Piper

Proposed CY 2026 Medicare Physician Fee Schedule Rule Signals Support for Digital Health Advancement

DLA Piper on

On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) issued the calendar year (CY) 2026 Medicare Physician Fee Schedule (MPFS) Proposed Rule (Proposed Rule). This client alert focuses on the proposed...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

Alston & Bird

Health Care Week in Review | Congress Passes Recissions Package, CMS Releases CY 2026 PFS and OPPS Proposed Rules

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

McDermott+

McDermott+ Check-Up – July 18, 2025

McDermott+ on

THIS WEEK’S DOSE - - OBBBA implementation begins. While the administration focuses on implementing the new law, some lawmakers are already discussing adjustments to health provisions in the One Big Beautiful Bill Act...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

McGuireWoods Consulting

Proposed Rule For The 2026 Medicare Physician Fee Schedule Released

On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) released its proposed physician fee schedule (PFS) rule. After five years of Medicare reimbursement reductions, CMS proposes a 3.8% increase in physician...more

Polsinelli

CMS Proposes New Mandatory, Two-Sided Risk Model for Heart Failure and Low Back Pain

Polsinelli on

Key Takeaways - CMS has proposed a mandatory two-sided risk model for specialists treating heart failure and low back pain in outpatient settings....more

Benesch

Dialysis & Nephrology Digest - July 2025

Benesch on

CMS Releases Proposed Rule for 2026 ESRD PPS - As the nephrology organization representing the specialty on socioeconomic and physician practice issues, the Renal Physicians Association analyzes and disseminates...more

McDermott+

CMS releases CY 2026 Physician Fee Schedule Proposed Rule

McDermott+ on

On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2026 Revisions to Payment Policies Under the Physician Fee Schedule (PFS) and Other Revisions to Medicare Part B [CMS-13271]...more

McDermott+

Digesting a giant reg: the CY 2026 Medicare Physician Fee Schedule proposed rule

McDermott+ on

Earlier this week, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed reg. Stakeholders have highly anticipated the release of this reg, as it...more

King & Spalding

CMS Escalates Aggressive Rates Cut in Home Health Prospective Payment System Proposed Rule for CY 2026

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On June 30, 2025, CMS issued its annual Home Health Prospective Payment System Proposed Rule for Calendar Year (CY) 2026 (the Proposed Rule). The Proposed Rule continues the agency’s policy of using provisions of the...more

McDermott+

Healthcare Preview for the Week of: July 14, 2025

McDermott+ on

Rescissions rescissions - Congressional focus this week is on the rescissions package and appropriations. The rescissions bill has a July 18 deadline to reach the president’s desk for signature. The bill is pending in the...more

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