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CMS Rescinds Post-Dobbs EMTALA Guidance, Raising New Questions for Emergency Departments

I. Key Takeaways - Federal enforcement under the Emergency Medical Treatment and Labor Act (EMTALA) may be changing after the Centers for Medicare & Medicaid Services (CMS) rescinded guidance issued under the Biden...more

HHS Under the Second Trump Administration

On February 11, 2025, President Trump signed Executive Order (E.O.) 14210, Implementing The President’s “Department of Government Efficiency” Workforce Optimization Initiative, which instructed the newly formed Department of...more

Department of Health and Human Services Seeks to Revise Rulemaking Policies

On Friday, February 28, 2025, the Department of Health and Human Services (HHS) issued a policy statement announcing changes to rulemaking processes for agencies within HHS. According to the statement, HHS is rescinding a...more

What President-Elect Trump’s Victory Means for Healthcare in 2025

Donald Trump will be the 47th President of the U.S. Not since 1892 has a President been elected to two non-consecutive terms, and his victory has helped Republicans pick up several critical seats in Congress. Senate...more

EMTALA Abortion Question Set Up for Supreme Court Review

As we’ve discussed in previous alerts (here and here), after the Supreme Court’s Dobbs decision, which eliminated the federal constitutional right to abortion and returned the question of abortion regulation to the states,...more

State Medicaid Redeterminations Following the End of the COVID-19 Era Continuous Enrollment Requirem

At the onset of the COVID pandemic in March of 2020, Congress made an important policy decision: continued access to health coverage was crucial, especially because, at the time, it was uncertain how the economy would...more

Competing EMTALA Decisions Underscore Complexity of Post-Dobbs Legal Landscape

In eliminating the federal constitutional right to abortion, the United States Supreme Court’s July 24, 2022 decision, Dobbs v. Jackson Women’s Health Organization, returned the question of abortion regulation to the “people...more

Two Lawsuits on EMTALA’s Role in a Post-Dobbs World

Following the Supreme Court’s decision in Dobbs, one federal law, the Emergency Medical Treatment and Labor Act (EMTALA), has become a focal point in the Biden administration’s efforts to challenge state attempts to restrict...more

Becerra v. Empire Health Foundation: Supreme Court Validates HHS Read of Medicare DSH Fraction Statute

June 27, 2022 Key Takeaways: Late last week, the Supreme Court released its opinion in Becerra v. Empire Health Foundation, a case that involves the complex but important question regarding how to calculate the Medicare and...more

Medicaid Provisions in COVID-19 Relief Package

Here at the Medicaid and the Law Blog, we spent part of our holiday break reading through the most recent COVID-19 relief package that was finally signed into law by President Trump amid a not-insignificant amount of drama. ...more

HHS Updates Medicaid Safety Net Payment Policies

Last month, we described the announcement by the Department of Health and Human Services (HHS) announcing the allocation to Medicaid providers under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. In the past...more

After Long Wait, HHS Announces Medicaid CARES Act Allocation

Well, we’ve been waiting for awhile and now it’s been made public: the Department of Health and Human Services (HHS) announced on June 9 that it was releasing $25 billion in funding from the Coronavirus Aid, Relief and...more

The COVID-19 Pandemic and Implications for Medicaid

Since the COVID-19 pandemic began to seriously affect the United States in March, Congress has passed four major pieces of legislation to address the public health crisis. CMS has also jumped into action and has issued a...more

MACPAC Expresses Concern Regarding Payments to High-Medicaid Providers During Coronavirus Pandemic

We haven’t posted on the blog in a while due to the rapid increase in our workload due to the coronavirus pandemic. We’re preparing a longer post that will go through everything that’s happened in Medicaid legislatively and...more

The COVID-19 Virus and Medicaid (UPDATED)

The global pandemic caused by the novel corona virus has certainly shaken up our normal way of life and will do so for the foreseeable future. Times like this reinforce the importance of public health insurance programs like...more

Washington D.C. Appellate Court Upholds Prohibition on Medicaid Work Requirement Waivers

The Centers for Medicare & Medicaid Services (CMS) suffered a big loss in court last week. The United States Court of Appeals for the D.C. Circuit upheld a lower court ruling that blocked CMS from implementing one of the...more

CMS Issues Guidance to States on 340B Duplicate Discounts

Late last year, we noted that the Massachusetts Medicaid program had proposed regulations to address issues related to the prohibition on duplicate discounts in the 340B program. The Massachusetts solution was relatively...more

Medicaid and Non-Emergency Medical Transportation

On June 19, the House of Representatives passed the funding bill for the Department of Health and Human Services for fiscal year 2020.  CMS is funded in this annual legislation and this funding bill is often a vehicle for...more

New Employee Benefit Rules Expand Health Reimbursement Arrangement Options for Employers

On June 13, 2019, the Internal Revenue Service (IRS), Department of Labor and Department of Health and Human Services (HHS) issued a new regulation that is intended to increase the use of tax-favored health reimbursement...more

The History of Rebates in the Drug Supply Chain and HHS’ Proposed Rule to Change Safe Harbor Protection for Manufacturer Rebates

Excerpt: I. Introduction - In February of 2019, the Department of Health and Human Services’ Office of Inspector General (HHS-OIG) issued a Proposed Rule that, if adopted, would upend the current prescription drug...more

Antitrust Implications of HHS' Proposed Rule to Limit Manufacturer Rebates - March 2019

In February of 2019, the Department of Health and Human Services’ Office of Inspector General (HHS-OIG) issued a Proposed Rule that, if adopted, would upend the current prescription drug rebate system. According to HHS-OIG,...more

Antitrust Implications of HHS Proposal to Limit Manufacturer Rebates

I. Introduction - In May 2018, the Department of Health and Human Services (HHS) introduced a “Blueprint” and Request for Information setting forth proposed actions and policies as a means to purportedly help lower...more

340B Hospitals File Suit in Wake of Hospital Outpatient Cuts

On November 13, 2017, a group of hospital trade associations (the American Hospital Association, the Association of American Medical Colleges, and America’s Essential Hospitals), along with two health system providers, filed...more

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