Steven Schnelle

Steven Schnelle

McDermott Will & Emery

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CMS Pushes to Expand Hospital Price Transparency Requirements, Enforcement Activity

On July 26, 2023, two days after the Centers for Medicare and Medicaid Services (CMS) issued its second largest civil monetary penalty for noncompliance with the hospital price transparency rule, CMS hosted a webinar...more

8/25/2023  /  Centers for Medicare & Medicaid Services (CMS) , Enforcement Actions , Health Care Providers , Healthcare , Healthcare Reform , Hospitals , Price Transparency , Proposed Rules , Public Comment

CMS Releases Proposed Remedy for 340B-Acquired Drugs Purchased in CYs 2018–2022

On July 7, 2023, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule, Hospital Outpatient Prospective Payment System: Remedy for 340B-Acquired Drugs Purchased for Calendar Years 2018–2022, to...more

7/11/2023  /  Centers for Medicare & Medicaid Services (CMS) , Comment Period , Drug Pricing , Health Care Providers , Hospitals , Medicare , Outpatient Prospective Payment System (OPPS) , Prescription Drugs , Proposed Rules , Section 340B

CMS Proposes Heightened Penalties and Additional Requirements under the Hospital Price Transparency Rule

On July 19, 2021, President Joseph R. Biden’s administration released a proposed rule that would increase penalties for hospitals that do not comply with the Hospital Price Transparency Rule, effective January 1, 2022. The...more

7/21/2021  /  Biden Administration , Centers for Medicare & Medicaid Services (CMS) , Comment Period , Compliance , Health Care Providers , Hospitals , Penalties , Price Transparency , Proposed Rules

HRSA Issues Proposed Rule Requiring Community Health Center Grant Recipients to Provide Certain Drugs to Low-Income Patients at...

On September 24, 2020, the Health Resources and Services Administration (HRSA) released a proposed rule that, if finalized, would require 340B-participating recipients of federal grants under Section 330(e) of the Public...more

9/29/2020  /  Drug Pricing , Executive Orders , HRSA , Low-Income Issues , Prescription Drugs , Proposed Rules , Public Health Service Act , Section 340B , Trump Administration

CMS Finalizes Hospital Price Transparency Requirements, Disclosure of Negotiated Rates

On November 15, the Trump Administration released a final rule requiring hospitals to publicly disclose hospital charges, including negotiated prices with third-party payers by January 1, 2021. We outline key considerations...more

11/19/2019  /  Centers for Medicare & Medicaid Services (CMS) , Civil Monetary Penalty , Cost-Sharing , Disclosure Requirements , Employer Group Health Plans , Final Rules , Hospitals , Outpatient Prospective Payment System (OPPS) , Proposed Rules

Proposed OPPS Changes for 2020: A Review of Four Key Proposals

The Centers for Medicare and Medicaid Services has released proposed updates to payment rates and regulations applicable to the Hospital Outpatient Prospective Payment System for Calendar Year 2020, including proposals...more

8/6/2019  /  Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Hospitals , Medicare , Outpatient Prospective Payment System (OPPS) , Price Transparency , Prior Authorization , Proposed Rules , Reimbursements , Section 340B
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