News & Analysis as of

Reimbursements Proposed Rules

American Conference Institute (ACI)

[Virtual Conference] 6th Annual Passport to Proficiency on Rx Drug Pricing & Rebate Fundamentals - November 4th - December 4th,...

ACI's virtual 6th Annual Passport to Proficiency on Rx Drug Pricing & Rebate Fundamentals will help you master the fundamentals, comprehend the consequences of new developments, and prepare for the complexities and nuances of...more

McGuireWoods LLP

CMS Proposes Reimbursement Changes for Remote Patient Monitoring

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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

Dickinson Wright

Telehealth Summer 2025: Collaboration Models, Enforcement Trends, and Reimbursement Guidance

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It has been a busy summer for telehealth updates. Following is a high-level summary of the latest developments. On June 6, 2025, the Office of Inspector General of the U.S. Department of Health and Human Services (the “OIG”)...more

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

Miles & Stockbridge P.C.

Proposed Medicare 2026 Physician Fee Schedule: What Health Care Providers Should Know

The Centers for Medicare and Medicaid Services (CMS) published its proposed 2026 Medicare Physician Fee Schedule on July 14. The agency’s announcement emphasized “significantly cutting spending waste, enhancing quality...more

Foley & Lardner LLP

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

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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

Blank Rome LLP

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

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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

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

ArentFox Schiff

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

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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

DLA Piper

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

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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

Hogan Lovells

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

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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

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

Nossaman LLP

AB 1033 – Should Eminent Domain Law’s $5,000 Appraisal Reimbursement be Increased?

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In California, the primary governing structure for condemnation suits is set forth within Title 7 of the California Code of Civil Procedure (CCP 1230.010, et. seq.), otherwise known as the Eminent Domain Act, which was...more

Fox Rothschild LLP

CMS Proposed Rule Decreases Physician Payments, Expands Telehealth, and Much More

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The comment period for the CMS CY 2025 Physician Fee Schedule (PFS) Proposed Rule recently closed on Monday, September 9th. Based on previous years, the Final Rule can be expected as soon as early November, taking effect...more

King & Spalding

CMS Issues IPPS and LTCH Final Rule for FY 2025

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On August 1, 2024, CMS filed a display copy of its final rule for Fiscal Year (FY) 2025 pertaining to the Inpatient Prospective Payment Systems (IPPS) for general acute care hospitals and long-term care hospitals (LTCHs) (the...more

ArentFox Schiff

The 2025 Proposed Hospital Outpatient Prospective Payment System and Physician Fee Schedule Rules: What Pharma Stakeholders Need...

ArentFox Schiff on

Pharma’s favorite summer pastime is back again: reviewing the Centers for Medicare & Medicaid Services (CMS) release of the 2025 proposed Hospital Outpatient Prospective Payment System (HOPPS) and Physician Fee Schedule (PFS)...more

Health Care Compliance Association (HCCA)

FDA Consolidates, Revises Informed Consent Guidance; 2018 Common Rule Not Addressed

Nearly nine years to the day the Food and Drug Administration (FDA) issued a draft “information sheet” on informed consent, the agency published a 66-page final guidance document on the topic—marking the first time since 1998...more

Cozen O'Connor

HHS Proposes $9 Billion Lump Sum Payment for Hospitals to Remedy Unlawful 340B Payment Reductions

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On Friday, July 7, 2023, the Centers for Medicare & Medicaid Services (CMS) published their long-awaited proposed remedy to the unlawful 340B drug payment reductions. Background: In 2018, CMS significantly reduced the...more

Parker Poe Adams & Bernstein LLP

Would the FTC's Noncompete Ban Prohibit Signing and Relocation Bonus Clawbacks?

The Federal Trade Commission (FTC) recently reported that it had received over 25,000 comments on its proposal to ban employment noncompetition agreements. Most of the discussion over the proposal involves traditional...more

Mintz - Health Care Viewpoints

CMS Proposed Rule for Refunding Overpayments Would Align With False Claims Act “Knowledge” Standard

The Centers for Medicare & Medicaid Services (CMS) proposed a rule late last year to harmonize the standard it would apply for providers to identify and refund overpayments with the “knowledge” standard under the False Claims...more

K&L Gates LLP

Recent Developments to the 340B Drug Pricing Program

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In this episode Victoria Hamscho, Andrew Ruskin, and Leah Richardson provide an update on key developments to the 340B Program. They discuss the effects of the Supreme Court’s decision earlier this year overturning 340B...more

McDermott Will & Schulte

District Court Vacates 340B Cuts, But Don’t Expect Immediate Payment Rate Restoration

On September 28, 2022, the US District Court for the District of Columbia vacated the 2022 rule under which the US Department of Health and Human Services (HHS) reduced Medicare Part B payments on 340B drugs paid under the...more

King & Spalding

SEC Issues Significant Private Fund Proposal: Standardized Prohibitions and Requirements

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On February 9, in a 3-1 vote, the SEC approved a rule proposal (the "Proposed Rule”) that represents a sea-change in the Commission’s approach to private funds, with the Proposed Rule including provisions that would impose on...more

Sheppard Mullin Richter & Hampton LLP

Executive Order on Promoting Competition in the American Economy: The Biden Administration Considers Drug Pricing Strategies While...

On August 10, 2021, the Centers for Medicare and Medicaid (“CMS”) published a proposed rule (“Proposed Rule”) to rescind the Most Favored Nation Model (“MFN Model”) interim final rule that was published on November 26, 2020...more

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