R. Christopher Raphaely

R. Christopher Raphaely

Cozen O'Connor

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Justice Department Continues Pattern of False Claims Act Suits Due to Alleged Kickbacks

On May 1, the federal government brought a False Claims Act (“FCA”) suit against three health insurers, as well as three insurance brokers. The Justice Department’s suit alleges that the insurers paid millions of dollars in...more

5/14/2025  /  Anti-Kickback Statute , Centers for Medicare & Medicaid Services (CMS) , Department of Justice (DOJ) , Enforcement Actions , False Claims Act (FCA) , Healthcare Fraud , Insurance Industry , Medicare , Medicare Advantage , OIG

[Event] Health Care & Life Sciences 2025 - December 5th, Philadelphia, PA

Cozen O'Connor will host Health Care & Life Sciences 2025, our annual in-person seminar exploring critical issues impacting health care and life sciences businesses. Join attorneys and professionals from our Health Care &...more

11/1/2024  /  Best Practices , Centers for Medicare & Medicaid Services (CMS) , Chevron Deference , Chief Legal Officers , Continuing Legal Education , Corporate Transparency Act , Deadlines , Delaware , Enforcement Actions , Events , Food and Drug Administration (FDA) , Foreign Nationals , Health Care Providers , Healthcare Facilities , Healthcare Workers , Hiring & Firing , Life Sciences , New Jersey , Non-Compete Agreements , Pennsylvania , Private Equity , State Attorneys General , Workplace Violence

CMS Releases Second Set of FAQs Regarding Good Faith Estimates to Uninsured and Self-pay Patients Under “No Surprises Act”

CMS continued to roll out guidance regarding the No Surprises Act. The latest guidance is the second set of FAQs regarding the Good Faith Estimate Requirement for uninsured and self-pay patients was issued on April 5, 2022....more

4/8/2022  /  Centers for Medicare & Medicaid Services (CMS) , Good Faith , Guidance Update , Surprise Medical Bills , Uninsured Patients

CMS Releases Final Stark Rules To Promote Value-Based Care

On Friday, November 20, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released final regulations to remove certain barriers to the implementation of physician compensation arrangements under value-based payment...more

11/24/2020  /  Centers for Medicare & Medicaid Services (CMS) , Compensation , Final Rules , Health Care Providers , Medicaid , Medicare , Physicians , Stark Law , Value-Based Payments

Pharma Price Disclosure Rule Struck Down: Will Hospital Price Transparency Rule Meet The Same Fate?

On June 16, the D.C. Circuit Court struck down the Centers for Medicare and Medicaid Services’ (“CMS”) rule issued in May 2019 requiring pharmaceutical companies to disclose the wholesale acquisition cost of drugs over $35 in...more

6/22/2020  /  Affordable Care Act , American Hospital Association , Centers for Medicare & Medicaid Services (CMS) , Medicaid , Medicare , Pharmaceutical Industry , Transparency , Trump Administration

CMS Releases Final ACO Regulations

This morning CMS released a final rule regarding its most popular program for accountable care organizations (ACOs), the Medicare Shared Savings Programs. The final rule is based on the proposed rule for the program that was...more

12/24/2018  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Medicare Shared Savings Program , Proposed Rules

The Medicare Shared Savings Program and the New Glide Path to Risk

With the first class of 82 Accountable Care Organizations (ACO) in the Medicare Shared Savings Program (MSSP) awaiting word on what the future holds for their participation in the program after January 1, 2019, the Centers...more

8/24/2018  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Medicare Shared Savings Program

Futures in Doubt of CMS’ New Mandatory Bundled Payment Models and Medicare Shared Savings Program Track 1+

Word spread quickly Monday (December 20, 2016) about CMS’ issuance of final regulations (to be published in the Federal Register on January 3, 2017) rolling out new mandatory bundled payments models for Acute Miocardial...more

12/27/2016  /  Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Incentives , Medicare , Medicare Access and CHIP Reauthorization (MACRA) , Medicare Shared Savings Program

CMS’ Long Awaited Final ACO Regulations for 2016 and Beyond: Major New Options and Plenty of Fine Tuning

Today, the Centers for Medicare and Medicaid Services (“CMS”) will publish final regulations (“Final Rule”) for its flagship pay-for-performance program, the Medicare Shared Savings Program, in the Federal Register. The Final...more

6/9/2015  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Final Rules , Medicare Shared Savings Program , Pay-for-Performance

CMS Announces Latest Group Of MSSP ACOs And May Allow ACOs To Remain As “Upside-Risk Only” Longer

December has been a busy month for CMS with respect to the Medicare Shared Savings Program (“MSSP”). Last week CMS announced that eighty-nine (89) more ACOs would begin participating in the MSSP starting in 2015, bringing the...more

12/30/2014  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Healthcare , Medicare Shared Savings Program

CMS Releases New Proposed Medicare Shared Savings Program Regulations

The Centers for Medicare and Medicaid Services (“CMS”) released proposed regulations for the Medicare Shared Savings Program (“MSSP”) on Monday December 1, 2014. The proposed regulations are scheduled to be published in the...more

12/4/2014  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Healthcare , Medicare , Medicare Shared Savings Program , Proposed Regulation

IRS Releases Guidance on Private Business Use, and ACOs and Management Contracts

On October 25, 2014, the Internal Revenue Service (the IRS) released Notice 2014-67 that provides interim guidance on (i) participation in the Medicare Shared Savings Program through an accountable care organization (ACO) and...more

11/5/2014  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Healthcare , IRS , Medicare , Medicare Shared Savings Program

CMS Announces Program to Fund ACO Growth, Extends Fraud and Abuse Waivers

The Centers for Medicare & Medicaid Services (“CMS”) announced a new initiative, the ACO Investment Model, on October 15, 2014. Under the model, ACOs which are made up of “providers [who] lack adequate access to … capital”...more

10/17/2014  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Fraud and Abuse , Healthcare , Infrastructure , Waivers

Special (Limited) CMS Offer to Settle Claims on Appeal

With little fanfare just before the Labor Day weekend, CMS announced a program in which it would enter into administrative agreements with eligible providers in exchange for the providers’ withdrawal of pending appeals...more

9/4/2014  /  Appeals , Centers for Medicare & Medicaid Services (CMS) , Healthcare , Hospitals , Recovery Audit Contractors (RACs) , Settlement

CMS and ACOs: A Busy Summer and a Busier Fall

It has been a busy summer so far for the Centers for Medicare & Medicaid Services (CMS) with respect to Accountable Care Organizations (ACOs), as the agency has proposed altering the quality reporting measures under the...more

8/6/2014  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Healthcare , Medicare Shared Savings Program , OMB

ACOs And Pay for Value … About the Data

It has been over three years since the Centers for Medicare and Medicaid Services (CMS) announced its proposed rule and guidance on the development and implementation of Accountable Care Organizations. About four million...more

7/25/2014  /  ACOs , Centers for Medicare & Medicaid Services (CMS) , Health Insurance Portability and Accountability Act (HIPAA) , Healthcare , Medicaid , Medicare , Patient Privacy Rights , Risk Assessment , Risk Management , Rulemaking Process
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