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More Losses than Gains? OIG Declines to Approve Certain Medicare Advantage Gainsharing Arrangements in Advisory Opinion 24-08

On September 13, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 24-08, in which it declined to approve a proposal by a Medicare Advantage organization (MAO)...more

CMS Finalizes New Mandatory Value-Based Payment Initiative: The Transforming Episode Accountability Model

On August 28, as part of its Fiscal Year 2025 Hospital Inpatient Prospective Payment System (IPPS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) finalized the Transforming Episode Accountability Model (TEAM)...more

CMS Proposes New Mandatory Value-Based Payment Initiative: The Transforming Episode Accountability Model

The Centers for Medicare & Medicaid Services (CMS) recently proposed the Transforming Episode Accountability Model (TEAM) – a new, mandatory, episode-based alternative payment model in the Fiscal Year 2025 Hospital Inpatient...more

CMS Finalizes CY 2025 Medicare Advantage Rule, Confirming Continued Focus on Marketing Practices and Health Equity

On April 4, the Centers for Medicare & Medicaid Services (CMS) issued the Contract Year (CY) 2025 Medicare Advantage (MA) Final Rule (Final Rule), which will have significant implications for MA plans and other industry...more

CMS Announces New MSSP Model Aimed at Improving Primary Care

The Centers for Medicare & Medicaid Services (CMS) recently announced the ACO Primary Care Flex Model (ACO PC Flex Model or Model), a new voluntary payment model for primary care furnished through low-revenue Accountable Care...more

New 2025 Medicare Advantage Proposed Rule Further Scrutinizes Marketing Practices, Expands Behavioral Health, and Promotes Health...

On November 15, CMS published a proposed rule, which, as currently written, has potentially significant implications for Medicare Advantage (MA) plans and Medicare Prescription Drug Benefit Program (PDP) plans in Contract...more

CMS Finalizes Long-Awaited RADV Program Rule

On February 1, the Centers for Medicare & Medicaid Services (CMS) published the Medicare Advantage (MA) Risk Adjustment Data Validation (RADV) Program Final Rule (Final Rule), which will take effect on April 3, 2023. The...more

HHS Updates Provider Relief Fund Reporting Guidance and Timelines

After months of quiet introspection, on June 11, 2021, the U.S. Department of Health and Human Services (HHS) released long-awaited updated Post-Payment Notice of Reporting Requirements, which outlines updated reporting...more

American Rescue Plan Act of 2021: Healthcare Highlights

Yesterday, President Biden signed into law the American Rescue Plan Act of 2021 (Act), which narrowly passed the U.S. Senate (50 – 49) and House of Representatives (220 – 211) earlier this week. The Act provides for $1.9...more

The No Surprises Act Passed and (Surprise!) Healthcare Providers are Leery of its Impact

After a drawn-out drafting-and-review process, the hotly contested No Surprises Act (Act) has made its way into law after being tucked into the 5,500+ pages of the Consolidated Appropriations Act, 2021, signed into law on...more

Newly Enacted End of Year Legislation Has Impact on Healthcare Providers

On December 27, President Trump signed into law the Consolidated Appropriations Act, 2021 (Act), which was passed by Congress the evening of December 21, after weeks of negotiation. The lengthy legislation, totaling in at...more

CMS and the OIG Issue Final Rules Modernizing and Clarifying the Federal Stark and Anti-Kickback Laws

In a coordinated effort, on November 27, 2020, the Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) published final rules to modernize regulations implementing the federal...more

HHS Changes Course: Requires Repayment of Excess Relief Funds Received

On December 4, the U.S. Department of Health and Human Services (HHS) revised its Public Health and Social Services Emergency Fund (Relief Fund) Frequently Asked Questions (FAQs), indicating that providers must return Relief...more

HRSA Releases Details on Provider Relief Fund Reporting Requirements

The Health Resources and Services Administration (HRSA) quietly released a Post-Payment Notice of Reporting Requirements (Notice) over the weekend, which provides some initial details regarding the reporting requirements...more

HHS Issues Guidance Regarding Relief Fund Reporting and Auditing Requirements

The U.S. Department of Health and Human Services (HHS) recently issued new guidance regarding reporting and auditing requirements that may impact providers and suppliers who retain payments received from the Public Health and...more

HHS to Distribute $25 Billion of Relief Funds to Medicaid & CHIP Providers and Safety Net Hospitals

On Tuesday, June 9, the U.S. Department of Health and Human Services (HHS) announced in a press release that it expects to distribute approximately $15 billion from the Public Health and Social Services Emergency Fund (Relief...more

CARES Act’s Impact on Healthcare: Financial Relief for Providers, Expanded Access to COVID-19 Care, Increased Resources and More

Financial Relief for Healthcare Providers - The CARES Act provides financial relief to healthcare providers that are being hit hard by the COVID-19 public health emergency. Perhaps most notably, the CARES Act establishes a...more

CMS and the OIG Issue Far-Reaching Proposed Rules to the Federal Stark and Anti-Kickback Laws

In a coordinated effort, CMS and the Office of Inspector General (OIG) published proposed rules to modernize regulations implementing the federal physician-self referral law, commonly referred to as the “Stark Law” (Stark),...more

Key Takeaways from CMS' New Proposed Rule on Stark Law Advisory Opinions

While the industry awaits more sweeping value-based related changes to the Stark Law regulations, on July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) took a small step toward updating its Stark Law advisory...more

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