News & Analysis as of

Outpatient Prospective Payment System (OPPS)

McDermott+

Healthcare Preview for the Week of: November 3, 2025

McDermott+ on

In last week’s Preview, we said this week would be one to watch for movement on the shutdown because of a few important dates. On November 1, 2025, the Affordable Care Act (ACA) Marketplace open enrollment began, where...more

McDermott+

CMS releases CY 2026 Physician Fee Schedule final rule

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On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) final rule, which includes policies related to Medicare physician payment and...more

McDermott+

The paradox: Declining Medicare payment rates versus higher Medicare spending

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McDermott+ is pleased to bring you Regs & Eggs, a weekly Regulatory Affairs blog by Jeffrey Davis. October 9, 2025 – Several recent Regs & Eggs blog posts have focused on comments that stakeholders submitted on two major...more

McDermott+

Blurred lines: Reactions to site neutral and site neutral lite policies

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McDermott+ is pleased to bring you Regs & Eggs, a weekly Regulatory Affairs blog by Jeffrey Davis. September 25, 2025 – We’ve enjoyed a buffet of comments on regs (and eggs) recently. In our last post, we discussed comments...more

Mintz

[Podcast] Health Law Diagnosed: Mintz IRA Update — Q3 2025 Edition

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In the latest episode of Health Law Diagnosed, Of Counsel Bridgette Keller is joined by Associate Hassan Shaikh for a discussion on noteworthy developments relating to the IRA and drug pricing. Together, Bridgette and Hassan...more

Benesch

HHS OIG Flags Explosive Part B Spending on Skin Substitutes Signaling Heightened Fraud, Waste, and Abuse Risk and Imminent Payment...

Benesch on

On September 5, 2025, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) Office of Evaluation and Inspections (OEI) released a Data Snapshot (OEI-BL-24-00420) finding that Medicare Part B...more

Mintz - Health Care Viewpoints

Mintz IRA Update — 340B Roundup: CMS Proposes Steeper OPPS Clawbacks, Launches Drug Cost Survey with Public Comment

In July 2025, CMS issued its 2026 Hospital Outpatient Prospective Payment System (OPPS) proposed rule, which includes two significant 340B policies. First, it includes cuts in the OPPS rates paid to hospitals to accelerate...more

American Conference Institute (ACI)

[Virtual Conference] 6th Annual Passport to Proficiency on Rx Drug Pricing & Rebate Fundamentals - November 4th - December 4th,...

ACI's virtual 6th Annual Passport to Proficiency on Rx Drug Pricing & Rebate Fundamentals will help you master the fundamentals, comprehend the consequences of new developments, and prepare for the complexities and nuances of...more

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | July 2025 Recap

This issue of McDermott Will & Schulte’s Healthcare Regulatory Check-Up highlights regulatory activity for July 2025, including the results of the US Department of Justice’s (DOJ) 2025 National Health Care Fraud Takedown, DOJ...more

Sheppard Mullin Richter & Hampton LLP

Proposed Medicare Payment Policies for Hospital Outpatient and Ambulatory Surgery Center Services

The Centers for Medicare & Medicaid Services recently published the calendar year (“CY”) 2026 proposed rule for Medicare payment for services provided in hospital outpatient departments under the Outpatient Prospective...more

Latham & Watkins LLP

Healthcare Life Sciences Drug Pricing Digest - July 2025 #2

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The Centers for Medicare & Medicaid Services (CMS) released the calendar year 2026 Physician Fee Schedule (PFS) proposed rule, which was published in the Federal Register on July 16, 2025. The comment period ends on September...more

McDermott Will & Schulte

Reducing hospital payments: CMS proposes expanded site-neutral payment policy for drug administration services

Consistent with recent attention from Congress and rhetoric from the Trump administration, the Calendar Year 2026 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule (the Proposed Rule) includes...more

King & Spalding

CMS Issues CY 2026 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed...

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On July 15, 2025, CMS issued a proposed rule with updates to the Medicare payment rates for the Hospital Outpatient Prospective Payment System (OPPS) and the Medicare Ambulatory Surgical Center (ASC) payment system for...more

McDermott+

Site neutrality is on the menu in the CY 2026 Medicare Outpatient Prospective Payment System proposed rule

McDermott+ on

Last week, the Centers for Medicare & Medicaid Services (CMS) issued two major regs: the calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule and the CY 2026 Outpatient Prospective Payment System (OPPS)...more

McDermott Will & Schulte

CMS CY 2026 proposed rules: 340B in PFS and OPPS

On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released the CY 2026 Outpatient Prospective Payment System (OPPS) proposed rule. The proposed rule includes a provision that would increase the reduction in...more

Holland & Knight LLP

Holland & Knight Health Dose: July 22, 2025

Holland & Knight LLP on

With the One Big Beautiful Bill Act (OBBB) passed by U.S. Congress and signed into law, Congress now has less than three weeks that it will be in session before government funding expires on Sept. 30, 2025. Appropriators will...more

Holland & Knight LLP

CMS Releases CY 2026 Outpatient Prospective, ASC Payment System Proposed Rule

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) on July 15, 2025, issued the Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems proposed rule, which proposes updates to the...more

Hogan Lovells

Medicare proposed rules include government pricing surprises: ASP changes and maximum fair price, new bona fide service fee and...

Hogan Lovells on

Every July, the Centers for Medicare & Medicaid Services (CMS) publishes two proposed rules relating to how it plans to administer the Medicare Part B program for the next calendar year: the physician fee schedule (PFS)...more

McDermott+

McDermott+ Check-Up – July 18, 2025

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THIS WEEK’S DOSE - - OBBBA implementation begins. While the administration focuses on implementing the new law, some lawmakers are already discussing adjustments to health provisions in the One Big Beautiful Bill Act...more

McDermott+

CMS releases CY 2026 Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System proposed rule

McDermott+ on

On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule [CMS-1834-P],...more

Parker Poe Adams & Bernstein LLP

How the Centers for Medicare and Medicaid Services 2025 Payment System Final Rule Impacts Ambulatory Surgical Centers

On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the 2025 hospital outpatient prospective payment system and ambulatory surgical centers (ASC) rule. The rule updates Medicare payment rates for...more

Bass, Berry & Sims PLC

CMS Finalizes Virtual Direct Supervision Extension and Rule Changes

Bass, Berry & Sims PLC on

On November 1, the Centers for Medicare & Medicaid Services (CMS) finalized its proposal to extend virtual direct supervision—i.e., the ability to provide direct supervision through real-time, audio-visual technology (rather...more

ArentFox Schiff

The 2025 Final Hospital Outpatient Prospective Payment System and Physician Fee Schedule Rules: What Pharma Stakeholders Need to...

ArentFox Schiff on

This past July, we reported on the Centers for Medicare & Medicaid Services (CMS) release of the 2025 proposed Hospital Outpatient Prospective Payment System (HOPPS) and Physician Fee Schedule (PFS) rules. CMS has now...more

King & Spalding

CMS Issues CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final...

King & Spalding on

On November 1, 2024, CMS issued a final rule with updates to the Medicare payment rates for the Hospital Outpatient Prospective Payment System (OPPS) and the Medicare Ambulatory Surgical Center (ASC) Payment System for...more

McDermott+

Another Trip to the Buffet: Highlights from the CY 2025 OPPS Final Reg

McDermott+ on

As mentioned last week, the Centers for Medicare & Medicaid Services (CMS) recently put out a large buffet of regs – too many to digest in one blog post. While we focused on the Calendar Year (CY) 2025 Physician Fee Schedule...more

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