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The Ongoing Saga of the CMS Hospital Price Transparency Rule

The Centers for Medicare & Medicaid Services (CMS) Hospital Price Transparency Rule went into effect on January 1, 2021, but whether it will succeed in making prices readily comparable for healthcare consumers remains to be...more

What Exactly Is a Hospital, Anyway? CMS Issues Guidance on “Primarily Engaged” Medicare Certification Requirement

The rules that govern participation in the Medicare program are notoriously voluminous and complex. Indeed, courts have described them as akin to a “[body of] law written by James Joyce and edited by E.E. Cummings” and “among...more

Key Points from the Final MACRA Rule

On October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released the final rule (Final Rule) implementing sweeping changes to the Medicare physician payment system mandated by the Medicare Access and CHIP...more

CMS Releases Final Rule to Implement Major Changes in Medicare Clinical Laboratory Payment Policy

On June 23, 2016, the Centers for Medicare and Medicaid Services (CMS) published a long-awaited final rule making major changes in the way Medicare will pay for clinical diagnostic laboratory tests (CDLTs). The changes were...more

MACRA/O Level Changes Coming with MIPS and APMs: An In-Depth Look at Medicare’s Proposed Physician Payment System Reform

1. Executive Summary - With the dirt barely settled on the unmourned grave of the Medicare sustainable growth rate (SGR) methodology for updating physician fee schedule payments, CMS published a proposed rule that would...more

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