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CMS Proposes to Codify the Definition of “Reasonable and Necessary” and to Establish a New Medicare Coverage Pathway

On September 1, 2020, CMS published a proposed rule that would define “reasonable and necessary” for purposes of coverage under Part A and Part B of the Medicare program, and that would establish a new expedited Medicare...more

CMS Releases FY 2021 Medicare IPPS and LTCH PPS Proposed Rule

On May 11, 2020, CMS issued its annual Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System Proposed Rule for FY 2021 (the Proposed Rule), which will affect...more

Coronavirus Update: CMS Guidance Issued this Month

As the number of coronavirus cases across the country continue to rise, CMS has issued several coronavirus-specific memorandums to healthcare providers and laboratories. In the past two weeks, CMS has issued disease-specific...more

OIG Approves Customer Loyalty Program Involving Pharmacy Products

On December 17, 2019, OIG published Advisory Opinion 19-06 approving a supermarket’s expansion of a loyalty program to allow customers to earn rewards points on out-of-pocket costs paid in connection with the purchase of...more

Eleventh Circuit Issues Decision Underscoring the Stark Law’s Favorable Treatment of Indirect Financial Relationships

In an opinion issued last Wednesday, the Eleventh Circuit affirmed the district court’s entry of final judgment in favor of a multi-state hospital system by dismissing the qui tam relator’s claims under the federal False...more

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