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Health Care Reimbursement Newsletter - January 2026

2026 is shaping up to be a pivotal year for health care reimbursement. From major CMS payment rules to evolving disclosure requirements, AI scrutiny, and mounting pressure on providers across the care continuum, the 2026...more

What 340B Hospitals Need to Know About CMS’s CY 2026 OPPS Final Rule

Key Takeaways - CMS launches Drug Acquisition Cost Survey beginning Jan. 1, 2026. OPPS hospitals must submit NDC-level pricing data for both 340B and non-340B drugs, which CMS will use to inform CY 2027 reimbursement...more

Ready or Not: HRSA’s 340B Rebate Pilot Model Takes Off Despite Questions on Readiness and Authority

Summary: On October 30, 2025 despite HRSA being impacted by the government shutdown, the agency approved 8 drug manufacturers / 9 drugs for participation in HRSA’s 340B Rebate Model Pilot Program (340B Rebate Pilot)....more

The 340B Rebate Pilot: Voluntary for Manufacturers, Costly for 340B Covered Entities

Key Takeaways - HRSA’s 340B rebate pilot shifts financial and operational burden to covered entities, requiring upfront drug purchases with delayed, uncertain rebate recovery....more

The OIG’s Concerns with Potentially Fraudulent Medicare Advantage Marketing

The HHS Office of Inspector General (“OIG”) released a Special Fraud Alert to inform health care professionals (“providers”) and Medicare Advantage Organizations (“MAOs”) about the OIG’s view of potentially abusive marketing...more

Medicare Continues its Updates to Provider Enrollment Policies as Part of Efforts to Enhance Program Integrity and Transparency

The Centers for Medicare & Medicaid Services (“CMS”) continued its efforts to increase oversight of the Medicare program by updating Medicare provider enrollment regulations and policies through recent regulatory and...more

CMS Announces Period of Enhanced Oversight for New Hospices in Arizona, California, Nevada, and Texas

Recently the Centers for Medicare & Medicaid Services (“CMS”) announced in a newly released MedLearn Matter (MLN7867599, July 2023) that effective as of July 13, 2021, any “new hospice agency” located in the states of Texas,...more

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