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Unpacking CMS's Proposed Rule for Correcting Underpayments for 340B Drug Reimbursement

In this episode, Darlene Davis, Leah Richardson, and Andrew Ruskin unravel CMS’s proposed rule for the remedy for Medicare payments for drugs purchased under the 340B Program and reimbursed as hospital outpatient services....more

340B Update: Appellate Court Upholds 340B Payment Reduction as CMS Proposes Further Reductions for 2021

In this week’s episode, Darlene Davis, Andrew Ruskin, and Gabriel Scott discuss notable recent developments for reimbursement under the Hospital Outpatient Prospective Payment System (“OPPS”) of drugs purchased under the 340B...more

340B Update: Appeals Court Upholds 340B Payment Reduction Under the OPPS as CMS Proposes Further Reductions for CY 2021

On 31 July 2020, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) upheld the U.S. Department of Health and Human Services’ (HHS) decision to allow the Centers for Medicare and Medicaid Services...more

340B Update: D.C. District Court Overturns OPPS 340B Reimbursement Cut for CY 2018

On December 27, 2018, the U.S. District Court for the District of Columbia sided with the plaintiffs by granting a permanent injunction striking down the reimbursement cut for drugs purchased under the 340B Drug Discount...more

340B Update for Hospitals: CMS Publishes FAQs Clarifying Use of Modifiers in Connection with 340B Program Reimbursement Cut on...

On December 13, 2017, the Centers for Medicare & Medicaid Services (“CMS”) published subregulatory guidance to answer questions about billing for drugs acquired through the 340B Drug Pricing Program (“340B Program”)...more

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