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Proposed Rules Reporting Requirements Centers for Medicare & Medicaid Services (CMS)

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

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

Blank Rome LLP

CMS Proposes New Rules for Calculating Average Sales Price for Medicare Part B Drug Reimbursement

Blank Rome LLP on

The Centers for Medicare & Medicaid Services (“CMS”) released the Calendar Year 2026 Medicare Physician Fee Schedule (“PFS”) proposed rule on July 16, 2025. (See...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

Ropes & Gray LLP on

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

ArentFox Schiff

Medicare 2026 Proposed Rules, Major Drug Pricing Updates, and What Stakeholders Need to Know

ArentFox Schiff on

Every July, the Centers for Medicare & Medicaid Services (CMS) publishes two proposed rules that set Medicare reimbursement and shape the administration of the Medicare Part B program for the upcoming calendar year. These...more

McDermott Will & Schulte

CMS CY 2026 proposed rules: 340B in PFS and OPPS

On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released the CY 2026 Outpatient Prospective Payment System (OPPS) proposed rule. The proposed rule includes a provision that would increase the reduction in...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

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

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

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

King & Spalding

CMS Reviews Quality Standards on Gender Transition Procedures

King & Spalding on

CMS announced in a letter released on Tuesday, May 27, 2025 (CMS Letter) that it will ramp up financial oversight of states to detect misuse of federal Medicaid funds “[t]o ensure that federal money is not used to pay for or...more

Ropes & Gray LLP

CMS Publishes Federal Fiscal Year 2026 Hospital Payment Proposed Rule

Ropes & Gray LLP on

On April 11, 2025, the Centers for Medicare & Medicaid Services (“CMS”) published its annual proposed rule for the federal fiscal year (“FFY”) 2026 inpatient prospective payment system (“IPPS”) and long-term care hospital...more

King & Spalding

CMS Issues Proposed FY 2026 PPS Rule for Inpatient Psychiatric Facilities

King & Spalding on

On April 11, 2025, CMS issued its fiscal year (FY) 2026 prospective payment system (PPS) proposed payment rule for inpatient psychiatric hospitals (IPFs). In addition to updating Medicare payment rates, adjustment factors,...more

King & Spalding

CMS Proposes 2.8% Payment Update for Skilled Nursing Facilities

King & Spalding on

On April 11, 2025, CMS proposed a rule that would update policies and payment rates used under the Skilled Nursing Facility (SNF) Prospective Payment System (PPS) for FY 2026 (Proposed Rule). The Proposed Rule also proposes...more

McDermott+

CMS Releases FY 2026 Hospital Inpatient Prospective Payment System (IPPS) Proposed Rule

McDermott+ on

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

McDermott Will & Schulte

CMS Implements First Major Updates to Lab Personnel Requirements in 30+ Years

On December 28, 2024, a long-awaited Centers for Medicare & Medicaid Services (CMS) final rule became effective, significantly updating laboratory personnel requirements under Subpart M of the Clinical Laboratory Improvement...more

Proskauer - Health Care Law Brief

CMS Proposes Additional Modifications to the Overpayment Rule Relating to the Deadline for Reporting and Returning Overpayments

In the context of Medicare Advantage (“MA”) reform initiatives, we previously addressed the Centers for Medicare & Medicaid Services’ (“CMS”) December 27, 2022 proposal to amend its regulations set forth at 42 C.F.R. §...more

King & Spalding

CMS Issues Hospice Proposed Payment Rule

King & Spalding on

Last week, CMS issued a proposed rule (Proposed Rule) for fiscal year (FY) 2025 aiming to update Medicare hospice payments and aggregate cap amount in accordance with existing statutory and regulatory requirements. The...more

McDermott+

CMS Releases Proposed Rule: Medicaid and CHIP Managed Care Access, Finance, and Quality

McDermott+ on

The proposed rule would make transparency-related updates to state directed payments (SDPs). It would also require states to submit an annual payment analysis that compares managed care plans’ payment rates for routine...more

McDermott+

CMS Releases Proposed Rule: Medicaid Program; Ensuring Access to Medicaid Services

McDermott+ on

On May 3, 2023 the Centers for Medicare & Medicaid Services (CMS) published the proposed rule Medicaid Program; Ensuring Access to Medicaid Services. The proposed rule seeks to increase transparency in payment rates,...more

King & Spalding

CMS Issues Proposed Rules to Update Medicare Payment Rates and Policies for Skilled Nursing Facilities and Inpatient Psychiatric...

King & Spalding on

On April 4, 2023, CMS issued proposed rules for Fiscal Year (FY) 2024 to update Medicare payment policies for skilled nursing facilities (SNFs) and inpatient psychiatric facilities (IPFs). CMS notes these rules are intended...more

King & Spalding

CMS Issues Outpatient Prospective Payment System Proposed Rule for CY 2022

King & Spalding on

On July 19, 2021, CMS published a proposed rule to update the payment policies, payment rates and other provisions for services furnished under the Medicare Outpatient Prospective Payment System (OPPS) and the Ambulatory...more

Holland & Knight LLP

CMS Releases FY 2022 IPPS and LTCH Proposed Rule

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) on April 27, 2021, released the Fiscal Year (FY) 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospital (LTCH) Prospective Payment...more

King & Spalding

CMS Issues Proposed Rules for Fiscal Year 2022 SNF and Hospice Payments

King & Spalding on

On April 8, 2021, CMS issued proposed rules for the Fiscal Year (FY 2022) Skilled Nursing Facility (SNF) Prospective Payment System (PPS) and FY 2022 hospice payments. CMS estimates that the aggregate impact of the payment...more

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