News & Analysis as of

Transparency Disclosure Requirements Centers for Medicare & Medicaid Services (CMS)

Lathrop GPM

Administration Issues Cross-Agency Guidance Targeting Health Care Pricing and Focusing on Hospitals and Health Plans

Lathrop GPM on

On May 22, 2025, the U.S. Department of Health and Human Services, Department of Treasury and Department of Labor (the “Agencies”) announced new steps intended to “strengthen healthcare price transparency.” ...more

Wiley Rein LLP

Trump Prioritizes Health Care Pricing Transparency in New Executive Order

Wiley Rein LLP on

On Tuesday, February 25, 2025, President Trump issued an Executive Order (EO), “Making America Healthy Again By Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information.” The EO aims to improve...more

Gardner Law

Sunshine Act Compliance: How to Take Action to Meet Reporting Requirements and Avoid Costly Penalties

Gardner Law on

The clock is ticking for medical device and pharmaceutical companies to fulfill their obligations under the Physician Payments Sunshine Act (the "Sunshine Act"). With the reporting deadline of March 31 looming and CMS...more

Davis Wright Tremaine LLP

Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

McDermott Will & Schulte

Biden Administration and CMS Propose New Rule to Provide Greater Transparency for Nursing Home Ownership

Following the Biden administration’s efforts to promote nursing home safety, transparency, accountability and quality, the US Centers for Medicare & Medicaid Services (CMS) announced a proposed rule governing nursing home...more

ArentFox Schiff

Proposed Nursing Home Disclosure Requirements Target Private Equity Companies and REITs

ArentFox Schiff on

On February 15, 2023, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule which would require greater disclosures of the ownership and management of Medicare and Medicaid nursing homes. Specifically,...more

Buchalter

New Patient Disclosure Requirement Effective January 1, 2023

Buchalter on

To increase transparency regarding payments to physicians by drug and medical device companies, Governor Newsom signed AB 1278, which imposes certain additional disclosure obligations on physicians. Beginning on January 1,...more

Alston & Bird

Impact of 2020’s Final Transparency Requirements on Employer-Sponsored Health Plans

Alston & Bird on

On October 29, 2020, the Centers for Medicare and Medicaid Services (CMS) along with the Department of Labor (DOL) and Treasury issued a final rule on price transparency to enable patients to accurately predict health care...more

Morgan Lewis

DC Circuit Court: CMS Rule on Drug Pricing Disclosure Exceeds Statutory Authority

Morgan Lewis on

In an informative decision for challenging rules that portend government overreach, the US Court of Appeals for the District of Columbia Circuit upholds the invalidation of the Centers for Medicare and Medicare Services’ drug...more

Sheppard Mullin Richter & Hampton LLP

Balancing Provider Pricing Transparency and Anti-Competitive Behavior

On November 15, 2019, CMS issued a final rule that requires hospitals to disclose to patients the hospital’s “standard charges,” which include the reimbursement rates the hospitals negotiate privately with insurers. This rule...more

King & Spalding

CMS Finalizes Rule to Require Hospitals to Disclose Negotiated Rates

King & Spalding on

The Department of Health and Human Services (HHS), and the Trump Administration as a whole, has placed a particular focus on the promotion of price transparency as a tool to control the costs of healthcare. In June, the...more

Tucker Arensberg, P.C.

Trump Administration Announces Historic Price Transparency Requirements

Tucker Arensberg, P.C. on

Attached are links to the CMS Press Release and the Trump Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First. The Trump Executive Order was first issued on June 21,...more

Faegre Drinker Biddle & Reath LLP

Will Prescription Drug Price Disclosures Have an Impact?

Colorado Passes New Law - The Colorado General Assembly recently passed new statute C.R.S. 12-42.5-308, which would require pharmaceutical manufacturer marketing employees or agents to present, at the time of marketing a...more

Mintz - Health Care Viewpoints

Pharmaceutical Companies Object to HHS Drug Pricing Disclosure Rule

Several parties from the pharmaceutical industry have teamed up with an advertising association to file a lawsuit against the Department of Health and Human Services (HHS) to prevent a new drug pricing disclosure rule from...more

McDermott Will & Schulte

Rethinking Transparency – Inpatient Prospective Payment System Final Rule Rescinds Proposed Survey Disclosure Rule

The 2018 IPPS/LTCH PPS proposed rule contained a provision that would have required AOs to make survey reports and acceptable plans of correction publicly available within approximately three months of issuance. The Final...more

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