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Centers for Medicare & Medicaid Services (CMS) Disclosure Requirements

Morgan Lewis - ML Benefits

CMS Disclosures Due October 15: Is Your Plan’s Rx Coverage Still Creditable?

The Inflation Reduction Act (IRA) made several changes to Medicare Part D that may impact whether employer-sponsored coverage will be creditable for the 2025 plan year. With open enrollment season about to begin, plan...more

BCLP

Selected Recent Developments for Public Companies

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Public companies should take note of several recent developments, including: ..Reversal of the Pegasystems trade secrets lawsuit that nevertheless preserves guidance to take care when describing litigation as “without...more

Venable LLP

June 1 Prescription Drug Reporting Deadline for Group Health Plans

Venable LLP on

Employer group health plans must make an annual disclosure of the plan's prescription drug and healthcare spending to the Centers for Medicare & Medicaid Services (CMS). The disclosure, called the Prescription Drug Data...more

ArentFox Schiff

The 10 Trends and Legal Challenges We Are Tracking Throughout 2024

ArentFox Schiff on

With 2024 well underway, this article highlights some of the pressing legal issues impacting the long term care and senior housing industry this year, including trends affecting the industry and emerging issues industry...more

Bass, Berry & Sims PLC

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

Bass, Berry & Sims PLC on

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

Mintz

EnforceMintz — 2023 Brings Uptick in Cybersecurity Enforcement, Insight Into Potential Risks

Mintz on

After the Department of Justice (“DOJ”) announced its Civil Cyber-Fraud Initiative in October 2021, many in the False Claims Act (“FCA”) bar expected an onslaught of enforcement actions and qui tam cases. The initiative...more

McDermott Will & Emery

Healthcare Regulatory Check-Up Newsletter | November 2023 Recap

McDermott Will & Emery on

This issue of McDermott’s Healthcare Regulatory Check-Up highlights regulatory activity for November 2023. We discuss several US Department of Health and Human Services (HHS) agency actions, including the new General...more

Davis Wright Tremaine LLP

Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

McDermott Will & Emery

Private Equity and REITs, Take Note! CMS Finalizes Nursing Facility Ownership Disclosure Requirements

McDermott Will & Emery on

On November 17, 2023, the US Department of Health and Human Services (HHS) published a final rule requiring nursing facilities participating in Medicaid and skilled nursing facilities participating in Medicare to disclose...more

Venable LLP

Looming CTA Disclosure Requirements and Healthcare Providers

Venable LLP on

The Federal Corporate Transparency Act (the CTA), 31 U.S.C. §5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...more

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

McCarter & English, LLP

Next Stop, Revalidation Station: CMS Final Rule for Nursing Home Transparency to Prompt Off-Cycle Revalidation, Revised Form...

Nursing facilities should prepare to provide the Centers for Medicare & Medicaid Services (CMS) with additional information about their ownership, their managing employees and the parties providing certain financial and...more

Goodwin

Additional Disclosure Required: CMS Implements Substantial Changes to Reporting Skilled Nursing Facility Ownership Information

Goodwin on

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule that will require skilled nursing facilities (SNFs) to disclose an expanded array of ownership, managerial, and control information...more

Genova Burns LLC

Heads Up To Group Health Plans: December 31 Gag Clause Attestation Deadline Approaches

Genova Burns LLC on

The Consolidated Appropriations Act of 2021 prohibits group health plans from agreeing to avoid making certain disclosures of provider-specific cost or quality-of-care information. This is referred to as the gag clause...more

Polsinelli

Ownership Transparency Continues for Skilled Nursing Facilities with Additional Required Disclosures

Polsinelli on

On November 15, 2023, CMS finalized a proposed rule that will require Skilled Nursing Facilities (“SNFs”) to disclose the identity of an expanded array of ownership and control interests in SNFs beyond the information that is...more

Polsinelli

What the Health Care Industry Needs to Know About the Corporate Transparency Act

Polsinelli on

A new federal law requires health care business entities to disclose personal information and photographs of persons with ownership and control over their business. The Centers for Medicare & Medicaid (CMS) and other federal...more

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

ArentFox Schiff

No More Surprise Medical Bills: Providers Score Yet Another Victory as Texas Court Again Vacates Provisions of Biden...

ArentFox Schiff on

On August 24, 2023, health care providers in Texas scored yet another victory when a federal court vacated additional portions of the Biden Administration’s rulemaking under the federal No Surprises Act (the Act). This marked...more

McDermott Will & Emery

Proposed Legislation Would Require Greater Transparency and Disclosure from Hospitals, Reduce Reimbursement to Certain Off-Campus...

McDermott Will & Emery on

Two bills are moving in the United States House of Representatives that have implications for hospitals and health systems, with material changes proposed regarding pricing transparency requirements, identification and...more

McDermott Will & Emery

Biden Administration and CMS Propose New Rule to Provide Greater Transparency for Nursing Home Ownership

McDermott Will & Emery on

Following the Biden administration’s efforts to promote nursing home safety, transparency, accountability and quality, the US Centers for Medicare & Medicaid Services (CMS) announced a proposed rule governing nursing home...more

McGuireWoods LLP

CMS Streamlines Stark Law Self-Disclosures

McGuireWoods LLP on

The Centers for Medicare & Medicaid Services recently announced updates to the voluntary self-referral disclosure protocol (SRDP), including revisions to streamline SRDP submissions. Providers and suppliers may report and...more

ArentFox Schiff

Proposed Nursing Home Disclosure Requirements Target Private Equity Companies and REITs

ArentFox Schiff on

On February 15, 2023, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule which would require greater disclosures of the ownership and management of Medicare and Medicaid nursing homes. Specifically,...more

Sheppard Mullin Richter & Hampton LLP

CMS Issues Proposed Rule Requiring Nursing Homes to Disclose Additional Ownership Information, Including Ties to Private Equity...

On February 15, 2023, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that would require nursing homes enrolled in Medicare and Medicaid to disclose new information about their ownership and...more

Mintz - Health Care Viewpoints

CMS Proposes New Disclosure of Ownership Regulations for Nursing Facilities - Top Five Takeaways for Private Equity Firms and...

Private equity (PE) ownership of health care providers is unquestionably under scrutiny by federal and state regulators. States are passing laws that either directly or indirectly target PE health care transactions. For...more

Ballard Spahr LLP

CMS Proposes Additional Disclosure Requirements for Nursing Facilities

Ballard Spahr LLP on

Summary - The Centers for Medicare & Medicaid Services (CMS) released a proposed rule (Proposed Rule) intended to require additional disclosures related to the ownership and management of nursing facilities that accept...more

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