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CMS Announces Proposed $9 Billion Remedy for Hospitals Underpaid by Unlawful Rate Cut for 340B Drugs

On July 7, 2023, CMS published its highly-anticipated proposed rule identifying its remedy to reimburse hospitals unpaid by its unlawful 340B drug payment policy (the Proposed Rule). While the Supreme Court found CMS’s 340B...more

CMS Issues Retroactive Final Rule Keeping Part C Days in the Medicare Fraction of the DSH Calculation

On June 7, 2023, CMS issued a final rule retroactively re-adopting its policy requiring patient days attributable to Medicare Part C beneficiaries (Part C days) to be counted in the Medicare fraction of the disproportionate...more

Court Rules on Retrospective Relief for 340B Hospitals Without Vacating CMS’s Rules

On January 10, 2023, Judge Contreras of the United States District Court for the District of Columbia ruled that CMS’s 340B drug reimbursement rates dating back to January 1, 2018, were unlawful and underpaid affected...more

Supreme Court Overturns Medicare Outpatient Drug Rate Cut for 340B Hospitals

On June 15, 2022, the Supreme Court issued a unanimous ruling in American Hospital Assn. v. Becerra declaring that CMS’s 2018 and 2019 reimbursement outpatient drug rate cut to 340B hospitals was “contrary to the statute and...more

United States Supreme Court Passes on Review of FCA Dismissal from Fifth Circuit Involving Alleged Medicare Overbilling

On December 7, 2020, the United States Supreme Court declined review of the U.S. Court of Appeals for the Fifth Circuit’s affirmation to dismiss a $61.8 million False Claims Act case alleging Medicare overbilling against a...more

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