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2021 OPPS and ASC Payment System Final Rule: Change Is the Only Constant

On December 2, 2020, the Centers for Medicare & Medicaid Services (CMS) released the calendar year 2021 Final Rule implementing changes to the Medicare hospital Outpatient Prospective Payment System (OPPS) and Ambulatory...more

HRSA Addresses Federal 340 Drug Discount Program Compliance Issues Affected by COVID-19

The Health Resources and Services Administration (HRSA) is the branch of the U.S. Department of Health and Human Services (DHHS) responsible for administering the federal 340B Drug Discount Program (340B Program). ...more

On the Coronavirus Front Line: Legal Issues for Healthcare Providers

As all employers confront the COVID-191 (coronavirus) pandemic, they must balance providing a safe and healthy work environment for their employees with a need to avoid potential liability when taking decisive, well-meaning...more

Supreme Court Overturns Disproportionate Share Hospital Payment Policy and Limits CMS Use of Subregulatory Guidance

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

Hospitals Subject to New Standards for Documenting 340B Program Eligibility

The Health Resources and Services Administration (“HRSA”), which is the branch of the U.S. Department of Health and Human Services that administers the federal 340B Drug Discount Program (“340B Program”), recently announced...more

Modernization? SAMHSA Falls Short in Updating 42 C.F.R. Part 2

On January 18, 2017, the Department of Health and Human Services Substance Abuse and Mental Health Services Administration (“SAMHSA”) published a final rule amending 42 C.F.R. Part 2 (“Part 2”), with an effective date that...more

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