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
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
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
On April 27,2022, the Office of Inspector General of the Department of Health and Human Services (OIG), Office of Evaluations and Inspections, issued a report on the performance of Medicare Advantage Organizations (MAOs) in...more
The Centers for Medicare and Medicaid Services (CMS) recently announced a redesign of the Global and Professional Direct Contracting Model (the GPDC Model) and renamed the GPDC Model the ACO REACH Model. (“REACH” stands for...more
On September 30, 2021, the U.S. Departments of Health and Human Services (HHS), Labor and Treasury (collectively, the Departments) along with the Office of Management and Budget released “Requirements Related to Surprise...more
On September 20, 2021 the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) issued a report suggesting that certain Medicare Advantage (MA) companies were leveraging chart reviews and...more
On August 13, 2021, the State of Illinois enacted a law, amending the Illinois Freedom To Work Act (the Law) to limit the enforceability of non-competition and non-solicitation agreements between employers and employees in...more
On July 19, 2021 the Centers for Medicare and Medicaid Services (CMS), as part of proposed rule covering a variety of subjects, including Medicare Hospital Outpatient and Ambulatory Surgery Center PPS modifications, issued a...more
Over the last several years, both the federal government and a number of state legislatures have sought to find a solution to the billing by out-of-network providers, referred to as “Out of Network Billing” (OON Billing) and...more
The Centers of Medicare and Medicaid Services (CMS) issued a Final Rule (the Rule) on April 29, 2021 extending and making various revisions to the Comprehensive Care for Joint Replacement Model (the CJR Model). The CJR Model...more
By letter dated April 13, 2021 (Letter), the Democrat and Republican leadership of the House Committee on Energy and Commerce and its Subcommittee on Health, wrote United States Health and Human Services Secretary, Xavier...more
On December 29, 2020, the United States Court of Appeals for the District of Columbia issued its opinion in American Hospital Association v. Azar (the Opinion) upholding the Hospital Transparency Regulation (the Rule) issued...more
1/13/2021
/ Administrative Procedure Act ,
Affordable Care Act ,
American Hospital Association ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Corrective Action Plans (CAPs) ,
Department of Health and Human Services (HHS) ,
First Amendment ,
Hospitals ,
New Regulations ,
New Rules ,
PHSA ,
Price Transparency ,
Public Disclosure ,
Secretary of HHS
On October 29, 2020 the United States Departments of Health and Human Services, Labor and Treasury (the Departments) issued a final rule entitled Transparency in Coverage (the Rule). The Rule continues on the Trump...more
11/5/2020
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Executive Orders ,
Final Rules ,
HCPCS ,
Health Insurance ,
Pharmacy Benefit Manager (PBM) ,
Public Disclosure ,
TPAs ,
Transparency ,
U.S. Treasury
COVID-19 has hit long-term care facilities very hard. Every day brings reports of lethal outbreaks in such facilities and one-quarter or more of the reported COVID-19 related deaths in the United States have been connected...more
On July 10, 2019, President Trump issued an Executive Order entitled Advancing American Kidney Health. The Executive Order stated that the “state of care for patients with chronic kidney disease and end-stage renal disease...more
On November 15, 2019, the Federal Government issued two rules: one in final form and one in proposed form, both designed to increase price transparency in health care. The rules follow on the Executive Order announced by...more
12/27/2019
/ Affordable Care Act ,
Comment Period ,
Department of Health and Human Services (HHS) ,
Employer Group Health Plans ,
Final Rules ,
Health Care Providers ,
Health Insurance ,
Health Plan Sponsors ,
Hospitals ,
Price Transparency ,
Proposed Rules
On July 10, 2019, the Centers for Medicare & Medicaid Services (CMS) and the Center for Medicare & Medicaid Innovation (Innovation Center) released a much awaited proposal for a new bundled payment model for radiation...more
8/6/2019
/ Bundled Payments ,
Cancer ,
Centers for Medicare & Medicaid Services (CMS) ,
CMMI ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Hospitals ,
Medicare ,
NPRM ,
Proposed Rules ,
Quality of Care Standards
Website accessibility under the Americans with Disabilities Act of 1990 (ADA) and Rehabilitation Act of 1973 (Rehabilitation Act) is an issue of which health care providers and other health care companies should be aware....more
A recent trend in suits filed under the Americans with Disabilities Act of 1990 (ADA) and the Rehabilitation Act of 1973 (Rehabilitation Act) includes claims for website accessibility. A number of entities have received...more
The Centers for Medicare and Medicaid Services (CMS) issued a final rule (the Rule) on December 21, 2018, which reshapes the Medicare Shared Savings Program (MSSP). Termed “Pathways to Success,” the Rule, among other...more
On August 9, 2018, CMS introduced a proposed rule that would substantially overhaul the Medicare Shared Savings Program (MSSP), requiring Accountable Care Organizations (ACOs) that participate in the MSSP to accept some...more
CMS recently announced that it wants to launch a new demonstration program, the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration. If approved and adopted as a demonstration project, the MAQI...more
On April 23, 2018, the Center for Medicare and Medicaid Innovation issued a Request for Information (the RFI) on a direct provider contracting model for primary care. The RFI seeks input on how direct provider contracting...more
Despite some initial difficulty in gaining momentum, the use of value-based payment methodologies will likely increase across all provider niches. This change is partly a function of cost savings driven by margin compression...more