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Recent Developments to the 340B Drug Pricing Program

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

2022 OPPS Final Rule Overview: CMS Finalizes Policies on 340B, Hospital Price Transparency, and Inpatient Only List

On 2 November 2021, the Centers for Medicare & Medicaid Services (CMS) released the 2022 Outpatient Prospective Payment System (OPPS)/Ambulatory Surgery Center (ASC) Payment System final rule (OPPS Final Rule), in which the...more

CMS Proposes to Increase Penalties for Hospital Price Transparency Noncompliance

On 19 July 2021, the Centers for Medicare & Medicaid Services (CMS) released the 2022 Outpatient Prospective Payment System/Ambulatory Surgery Center Payment System proposed rule (OPPS Proposed Rule),1 which includes a...more

340B Update: Supreme Court Accepts Certiorari in 340B Payment Reduction Case

On 2 July 2021, the Supreme Court announced that it has accepted the American Hospital Association’s (AHA) petition for certiorari in American Hospital Association v. Becerra. At issue is the Centers for Medicare and Medicaid...more

Hospitals Ask Supreme Court to Reverse Site-Neutral, 340B Payment Rulings

How far can an agency go to allow agency-developed policy objectives to supersede concerns about faithful adherence to the law? Similarly, how much should health systems and others regulated by Medicare be concerned about...more

K&L Gates Reimbursement Corner: CMS's Proposed Phase-Out of the Inpatient Only List is Not Entirely Welcome News

In a year where COVID-19 has occupied much of the activity for the staff responsible for the Hospital Outpatient Rule, there have still been some significant changes in this year’s proposed rulemaking. One in particular will...more

340B Update: Appellate Court Upholds 340B Payment Reduction as CMS Proposes Further Reductions for 2021

In this week’s episode, Darlene Davis, Andrew Ruskin, and Gabriel Scott discuss notable recent developments for reimbursement under the Hospital Outpatient Prospective Payment System (“OPPS”) of drugs purchased under the 340B...more

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