On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more
12/27/2023
/ Business Ownership ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Disclosure Requirements ,
Federal Trade Commission (FTC) ,
Final Rules ,
Hart-Scott-Rodino Act ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Premerger Notifications ,
Private Equity ,
REIT ,
Skilled Nursing Facility ,
Transparency
There are three things that cannot be stopped: time, gravity, and the increasing complexity of the Stark Law. To be fair, complexity has not been the goal of the Centers for Medicare & Medicaid Services (CMS). Rather, Stark's...more
On June 3, 2019, the U.S. Supreme Court issued its decision in Azar v. Allina Health Services, et al., Case No. 17-1484. The Court ruled in favor of a group of hospitals in a dispute over Medicare disproportionate share...more
6/12/2019
/ Administrative Procedure Act ,
Azar v Allina Health Services ,
Department of Health and Human Services (HHS) ,
Hospitals ,
Low-Income Issues ,
Medicare ,
Medicare Advantage ,
Medicare Part A ,
Medicare Part C ,
Notice and Comment ,
Pay Reductions ,
Provider Payments ,
Reaffirmation ,
Retroactive Application ,
SCOTUS ,
Substantive Rule ,
Vacated
The Office of Inspector General (“OIG”) of the Department of Health and Human Services has issued a final rule (“Final Rule”) adding new safe harbors to the federal anti-kickback statute, amending existing safe harbors, and...more
1/16/2017
/ Anti-Kickback Statute ,
Civil Monetary Penalty ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
FQHC ,
Generic Drugs ,
Health Care Providers ,
Medicare ,
OIG ,
Pharmacies ,
Remuneration ,
Rural Areas ,
Safe Harbors
On Feb. 12, 2016, CMS published the much anticipated final regulations implementing the so-called “60-Day Rule.” Congress adopted the 60-Day Rule as part of the Affordable Care Act (ACA). The Rule requires health care...more
Please join Davis Wright Tremaine partners Bob Homchick and Adam Romney, and associate Kyle Gotchy for a briefing regarding the final rule for the Comprehensive Care Joint Replacement (CJR) Program.
They will discuss the...more
The federal physician self-referral ban or Stark law has been a part of the legal landscape for almost 25 years. The breadth of the law’s prohibitions, its strict liability formulation and draconian remedies have made it the...more
7/28/2015
/ BPCI ,
Centers for Medicare & Medicaid Services (CMS) ,
False Claims Act (FCA) ,
Healthcare ,
Hospitals ,
Medicaid ,
Medicare ,
Medicare Shared Savings Program ,
Physician Fee Schedule ,
Physicians ,
Qui Tam ,
Relators ,
Stark Law ,
Tuomey
Last week, the Centers for Medicare & Medicaid Services (CMS) released its Final Rule on the Medicare Shared Savings Program (MSSP). The Final Rule provides additional flexibility to accountable care organizations...more
Last week, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses on...more
The U.S. Department of Health & Human Services, Office of Inspector General ("OIG") just released a proposed rule (“Proposed Rule”) that provides long awaited guidance on patient transportation services, relaxes the...more
10/6/2014
/ Affordable Care Act ,
Anti-Kickback Statute ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Gainsharing ,
Hospitals ,
Medicaid ,
Medicare ,
Medicare Part D ,
OIG ,
Physician Payments ,
Physicians ,
Proposed Regulation ,
Retailers ,
Transportation Expenses