News & Analysis as of

Administrative Law Judge (ALJ) Notice and Comment

Baker Donelson

HHS Memorandum Clarifies CMS Obligations Following Supreme Court Allina Decision

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In response to the disruptive Supreme Court decision on the impact and effect of administrative guidance, HHS has issued a memorandum suggesting that CMS's ability to enforce some of its payment policies may be limited by the...more

Baker Donelson

Azar v. Allina Health Services: Making Waves in Medicare Claim Appeals?

Baker Donelson on

When ruling that notice-and-comment procedures may be required for Medicare guidance, the Supreme Court may not have foreseen the potential disruptive impact on Medicare coverage rules....more

Baker Donelson

Florida's Emergency Generator Rules Invalidated

Baker Donelson on

On Friday, Judge Garnett W. Chisenhall, a duly-designated administrative law judge of the Florida Division of Administrative Hearings, issued a ruling invalidating emergency rules requiring all Florida nursing homes and...more

Bracewell LLP

PHMSA Implements New Emergency Safety Authority Effective Immediately

Bracewell LLP on

On October 3, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced an Interim Final Rule (IFR) establishing when and how it will issue Emergency Orders to address imminent safety hazards across...more

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