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CMS Announces Early Termination of the ESRD Treatment Choices (ETC) Model - Financial and Operational Implications for...

On March 12, 2025, the CMS announced its intent to terminate the ESRD Treatment Choices (“ETC”) Model as of December 31, 2025, two years ahead of its original end date....more

CMS Announces a Second Preview Period for the October 2024 SNF Preview Reports

On September 19, 2024, CMS announced a second preview period for the October 2024 SNF Preview Reports (“Preview Reports”) following the identification of a technical glitch that prevented the posting of these reports for...more

CMS announces Policy Changes and Updates for the CKCC Model - Any KCE PY 2024 Risk Option selections must be submitted by April...

We encourage all CKCC Model participants to review these updates carefully and take necessary actions to ensure compliance with the deadlines for KCE CKCC Model Performance Year 2024 Risk Option selections....more

HHS and FDA Release Updated Guidance on Informed Consent

On March 1, 2024, the US Department of Health and Human Services (HHS) Office for Human Research Protections (OHRP) and the US Food & Drug Administration (FDA) unveiled a preliminary guidance document named Enhancing...more

Indiana New Law Requires Written Notice of Mergers or Acquisitions of Healthcare Entities

On March 13, 2024, Indiana Governor Eric Holcomb enacted Senate Enrolled Act No. 9  (“Indiana Law”) into law, mandating that Indiana healthcare entities and private equity firms notify the Office of the Indiana Attorney...more

Dialysis & Nephrology Digest - December 2023

Fresenius continues business consolidation with sale of fertility business for $545M - A consortium consisting of KKR portfolio company IVI RMA and Spanish PE firm GED Capital agreed to pay €500 million for Eugin Group,...more

New State Healthcare Antitrust Laws Require Pre-Closing Notice for Certain Healthcare Transactions

During the past year, a number of states have enacted antitrust legislation relating to healthcare entities, which, once effective, will implement a dedicated health care transaction review process by relevant state agencies....more

Dialysis & Nephrology Digest - November 2023

Fresenius hiring Ascension Capital exec to head care delivery - The appointment of Craig Cordola as CEO of the dialysis company’s care delivery segment takes effect Jan. 1. He was at Ascension Capital for the past six...more

Dialysis & Nephrology Digest - October 2023

Federal Law increases competition in organ procurement, transplant system; NKF, ASN approve - The President signed the bipartisan bill into law on Sept. 22. The Organ Procurement and Transplantation Network (OPTN) was...more

Dialysis & Nephrology Digest - September 2023

FTC, DoJ propose changes to HSR Act for more effective, efficient merger reviews - The FTC, along with the Assistant Attorney General of the Antitrust Division, proposed changes to the premerger notification form and...more

Dialysis & Nephrology Digest - August 2023

NY non-compete ban still receiving pushback as Governor waits to sign off - While NY Governor Kathy Hochul waits to sign off on one of the country’s toughest bans on non-compete agreements, many lobby groups from the...more

Dialysis & Nephrology Digest - July 2023

Benesch: NLRB decision overturns use of ‘entrepreneurial opportunity’ super factor for classifying employees - Benesch explains the labor board’s decision retains the 10-point test to determine who can be considered an...more

Nephrology & Dialysis Conference Panel Key Take Aways - Value Based Care: Operationalizing Your VBC Organization to Ensure Success

The shift in health care from a retrospective fee for service (“FFS”) model to a value based care (“VBC”) model is growing across our nation’s health system and different specialties, including nephrology. VBC models in...more

Dialysis & Nephrology Digest - June 2023

Benesch: MN ban on non-compete agreements includes carveout for business sale, dissolution - Benesch Law notes the bill only awaits the signature of MN’s Governor and could become law as early as July 1. It would prevent...more

CMS Updates Guidance on Home Dialysis Services Provided in Nursing Homes

On March 22, 2023, the Centers for Medicare and Medicaid Services (“CMS”) issued revised Guidance and Survey Process for Reviewing Home Dialysis Services in a Nursing Home (Rev QSO-18-24-ESRD) to State Survey Agency...more

Dialysis & Nephrology Digest - May 2023

MedPAC recommends no additional increase in payments for dialysis in 2024 - MedPAC’s report on outpatient dialysis services recommends Congress not increase Medicare payments for dialysis services next year beyond the...more

Dialysis & Nephrology Digest - April 2023

ME trial reminiscent of DaVita anti-poaching case that also ended in acquittal; DOJ strategy questioned - In Apr. 2022, juries in TX and CO acquitted healthcare companies charged by the DOJ’s Antitrust Division. In the CO...more

Dialysis & Nephrology Digest - March 2023

Correction to our January 31, 2023 newsletter article, “Dialysis Provider Satellite Healthcare Reports Data Breach Affecting Nearly 100k Patients”: Media Statement, Satellite Healthcare - In January 2023, Satellite...more

Dialysis & Nephrology Digest - January 2023 #2

Benesch: Changes to state laws mean IL employers should review their employment practices - In IL, legislation affecting workplaces went into effect at the beginning of the year, including: ..The minimum wage was...more

Dialysis & Nephrology Digest - January 2023

Federal omnibus spending bill rolls back some Medicare payment cuts scheduled for 2023, 2024 - Buried within the $1.7-trillion spending package signed by the President on Dec. 29 was partial relief for a planned 4.5% cut...more

FTC Strikes Down Non-Competition Agreements and Proposes Ban on Non-Competition Agreements that Could Impact the Healthcare...

The Federal Trade Commission’s (“FTC”) threats of “cracking down” on non-competition agreements transformed into actual action with two dramatic moves this week. First, on January 4, the FTC ordered three companies,...more

Dialysis & Nephrology Digest - December 2022

Benesch: AKS claims against Azura dropped; FCA allegations to continue with DOJ intervention - The DOJ filed an Amended Intervenor Complaint in Aug. alleging between 2012 and 2018, Fresenius Medical Care’s business unit,...more

Dialysis & Nephrology Digest - November 2022

Benesch: DOL proposed rule aims to clarify independent contractor classification - The Department of Labor (DOL) proposes changes to the Fair Labor Standards Act to clarify the difference between an independent contractor...more

Dialysis & Nephrology Digest - October 2022

Benesch outlines five states with data protection laws coming into effect in 2023 - Next year, statutes for data security and data privacy will go into effect in CA and VA on Jan. 1, while laws in CO and CT will be...more

Dialysis & Nephrology Digest - September 2022

Fresenius CEO resigning; to be replaced by head of company’s pharmaceutical business - Michael Sen, President and CEO of Fresenius Kabi, will replace Stephan Sturm as CEO of Fresenius SE on Oct. 1. Shares in the company...more

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