U.S. Supreme Court ruling expands scope of Medicare notice-and-comment requirement

Ken Choe, Elizabeth Halpern, James Huang, Sheree Kanner, Stuart Langbein, Victoria Wallace
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On 3 June 2019 the U.S. Supreme Court held in Azar v. Allina Health Services that Medicare interpretive guidance must go through notice-and-comment if it establishes or changes a substantive legal standard governing payment, coverage, or eligibility.

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