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Massachusetts: Expansion of Oversight Authority — New Notice of Material Change Form for Health Care Transactions

The Massachusetts Health Policy Commission (the HPC), an independent state agency that works to improve affordability of health care for residents of the Commonwealth, released Advance Guidance (before finalization of new...more

Medicare Payment Model Trends and Economic Drivers – Awaiting Direction from Trump Administration

The Medicare program continues to face long term financial pressures associated with inflationary effects on health care costs and the growing wave of aging baby boomers. The Medicare Trust Fund, which is often viewed as a...more

Massachusetts: New Year, New Law — Governor Signs “An Act enhancing the market review process” (House Bill No. 5159)

On January 8, 2025, Governor Maura Healey signed into law H.B. 5159, “an Act enhancing the market review process.” This new law promises sweeping reform to reshape how health care businesses operate and grow...more

Massachusetts “Patients First Act” Implementation and Enforcement Re-Extended

The Massachusetts Senate proposed an amendment on Monday December 2, 2024, that would delay implementation and enforcement of the 2021 Patients First Act addressing health care cost transparency. Section 31 of the amendment...more

Risk Bearing Entity Requirements: An Introduction

Providers and provider organizations are increasingly contracting with payors to manage specific patient pools and diseases on a risk basis. They are taking new and increasing financial risk to better align with payors’...more

New HCPCS for Advanced Primary Care Management

The Center for Medicare & Medicaid Services (CMS) issued the display copy of the final Calendar Year 2025 Physician Fee Schedule on November 1, 2024, which included three new Healthcare Common Procedure Coding System (HCPCS)...more

Private Equity Investments in Oncology: Top Five Things to Know

Although private equity (PE) sponsors have been active investors in the health care services industry for the last decade, PE-backed health care providers today constitute only 4% of the United States health market by...more

Artificial Intelligence: Is the Health Care Sector Ready for the Rollout?

On July 17, 2024, Foley & Lardner LLP hosted the Boston Health Care AI & Technology Investor Summit with Endeavor Venture Funds, bringing together hundreds of attendees in person and virtually to discuss issues surrounding...more

Massachusetts Health Care Act Dies at the End of Legislative Session But Previews Sweeping Changes for the Health Care Industry

The Massachusetts legislative session officially closed on August 1, 2024 after an unusual half day extension. The 193rd legislative session left many omnibus bills unpassed, including S.B. 2881, “an Act enhancing the market...more

The No Surprises Act: The Departments Proposed Another Increase to IDR Fee, Will it Stick?

On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...more

Gender Affirming Care in Florida: Current Rules of the Road

Special thanks to summer associate Sheridan Organ for her contributions to this article. On May 4, 2023, the Florida Senate passed SB 254 by a sweeping vote of 83 to 23. This law, which imposes restrictions on...more

The No Surprises Act: A District Court’s Decision Results in Federal IDR Outage

Although the No Surprises Act was signed into law almost three years ago and has been in effect for the past year and a half, there have been numerous delays in implementation and execution due to the complexity of elements...more

Gender Affirming Care Restricted Under Missouri Bill

On May 10, 2023, the Missouri legislature passed a bill restricting access to gender affirming care for individuals under the age of 18. The bill is now headed to Governor Parson’s desk for signature...more

Florida’s Bill Targeting Gender Affirming Care Impacts Minors and Adults

On May 4, 2023, SB 254 passed the Florida Senate by a safe majority vote of 83 to 28 and is now on Governor DeSantis’s desk for approval. Once signed (expected shortly) , this law will take immediate effect and disrupt the...more

Payor/Provider Convergence and What It Means for You

Welcome to the Payor/Provider Convergence Series of the Health Care Law Today blog. This series is dedicated to exploring the intersection between payors and providers in the health care space; in particular, the evolving...more

CMS Extends Delayed Enforcement of the Good Faith Estimate

On Friday, December 2, 2022, the Centers for Medicare & Medicaid Services (CMS) issued an FAQ regarding the Good Faith Estimate (GFE) and Convening Provider/Facility requirements in the Federal No Surprises Act. The issued...more

Compliance Officers Lookout! DOJ and OIG Tag Team Corporate Integrity Agreements

The Office of Inspector General of the U.S. Department of the Health and Human Services (OIG) recently changed the language describing a compliance officer’s role in relation to other responsibilities he or she may have...more

CMS Reports Medicare Shared Savings Program Saved Medicare $1.66 Billion in 2021

On August 30, 2022, the Centers for Medicare & Medicaid Services (CMS) announced that the Medicare Shared Savings Program (MSSP) had saved the Medicare program $1.66 billion in 2021 as compared to spending targets, while...more

Proposed Revisions to Medicare Shared Savings Program: CMS Encourages Participation

The Centers for Medicare and Medicaid Services (CMS), as part of 2023 Physician Fee Schedule proposed rule, has proposed significant revisions to the Medicare Shared Savings Program (MSSP). The revisions to the MSSP in the...more

Postponement in the Massachusetts Patients First Act Penalties

On July 5, 2022, the Commonwealth of Massachusetts re-extended the implementation and enforcement date for the “Patients First Act”, sometimes referred to as the Massachusetts No Surprises Act, to January 1, 2025. As...more

Price Transparency Enforcement is Here – Hospitals Beware

On June 7, 2022, after months of written warnings, the U.S. Centers for Medicare & Medicaid Services (CMS) has levied its first fines nationwide on two affiliated Georgia hospitals for violations of CMS’ Hospital Price...more

No Surprises Act Challenges, Win for Providers

On Wednesday, February 23, 2022, U.S. District Court Judge Jeremy Kernodle of the Eastern District of Texas granted the Texas Medical Association’s and Adam Corley’s (the Plaintiffs) motion for summary judgment on their...more

How does the Federal No Surprises Act Impact Telemedicine Providers? Part Two

In this second installment of this blog series on the No Surprises Act interim regulations (NSA) we discuss: i) notice and consent requirements for out of network providers providing services at participating health care...more

How does the Federal No Surprises Act Impact Telemedicine Providers? Part One

In this two-part blog series, we dive into the key points for telemedicine providers in the several hundred pages of the No Surprises Act interim regulations (NSA). The good news for the telemedicine industry is that the...more

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