News & Analysis as of

Physician Fee Schedule

Paul Hastings LLP

New CMS Requirements for Average Sales Price Reporting: What Pharmaceutical Manufacturers Need to Do by April 30

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The Calendar Year 2026 Physician Fee Schedule Final Rule includes several targeted, but material, changes to the average sales price (ASP) calculation and reporting that directly impact pharmaceutical manufacturers, with...more

Tucker Arensberg, P.C.

CMS Announces New Mandatory Payment Model Targeting Cardiologists for Heart Failure Care

The Centers for Medicare & Medicaid Services (CMS) recently announced a new payment initiative that will require certain cardiologists to participate in a value-based reimbursement model focused on heart failure care. This...more

Polsinelli

Health Care Reimbursement Newsletter - January 2026

Polsinelli on

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

Burr & Forman

CMS Makes Permanent Significant Changes to Medicare Physician Supervision Rules

Burr & Forman on

As part of its calendar year 2026 Medicare Physician Fee Schedule, the Centers for Medicare and Medicaid Services (“CMS”) made permanent a major change to its physician direct supervision rules. Effective January 1, 2026, for...more

Tucker Arensberg, P.C.

2026 Medicare Physician Fee Schedule

The final Medicare Physician Fee Schedule for 2026 has now taken effect. Under the new rule, Center for Medicare Services (CMS) finalized two separate Medicare conversion factors depending on participation in a qualifying...more

McDermott Will & Schulte

ASP reporting gets a major update in the CY 2026 PFS

McDermott Will & Schulte on

Drug manufacturers, group purchasing organizations, and other companies in the drug distribution chain will be impacted by the changes to average sales price (ASP) and bona fide service fees (BFSFs) adopted by the Centers for...more

McDermott+

Season’s greetings: Holiday healthcare wishes from McDermott+

McDermott+ on

Happy holidays! We are coming to the end of 2025, and what a year in healthcare it was! With a new administration, the Centers for Medicare & Medicaid Services (CMS) and other federal agencies have been extremely busy...more

Ankura

Medicare Finalizes 3.8% Physician Reimbursement Increase

Ankura on

On Oct. 31, the Centers for Medicare and Medicaid Services (CMS) released the 2026 Physician Fee Schedule Final Rule (Final Rule), which outlines the changes to payments under the Medicare Physician Fee Schedule (PFS) for...more

Epstein Becker & Green

Ambulatory Specialty Model Final Rule: Bringing Specialists into Value-Based Payment

Epstein Becker & Green on

On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the final rule for the Calendar Year (CY) 2026 Medicare Physician Fee Schedule, which finalized the Ambulatory Specialty Model (ASM), targeting...more

Holland & Knight LLP

Holland & Knight Health Dose: December 3, 2025

Holland & Knight LLP on

Following a brief Thanksgiving holiday break, U.S. Congress faces just a handful of legislative days before year-end, and the next two weeks promise a crowded calendar as lawmakers race to meet major deadlines....more

Benesch

CMS Finalizes Mandatory Ambulatory Specialty Model for Heart Failure and Low Back Pain Specialists

Benesch on

On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) finalized the Ambulatory Specialty Model (ASM) in the CY 2026 Medicare Physician Fee Schedule (PFS) final rule. ...more

Hogan Lovells

CY 2026 Physician Fee Schedule Final Rule Update: Preliminary ASP Reasonable Assumption and BFSF Certification Forms Available

Hogan Lovells on

On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the physician fee schedule (PFS) final rule for calendar year (CY) 2026 (Final Rule). ...more

ArentFox Schiff

Update on CMS 2026 Physician Fee Schedule Final Rule: Key Takeaways for Pharma

ArentFox Schiff on

After issuing the Physician Fee Schedule (PFS) on October 31, the Centers for Medicare & Medicaid Services (CMS) has now published templates for manufacturers to utilize when complying with new requirements regarding the...more

McDermott+

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

McDermott+ on

On November 21, 2025, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System final...more

Sheppard

CMS Finalizes Mandatory Ambulatory Specialty Model for Cardiology and Low-Back Pain

Sheppard on

The Centers for Medicare & Medicaid Services (“CMS”) recently finalized a rule establishing the new Ambulatory Specialty Model (“ASM”)— a mandatory value-based payment model that could apply to nearly one-quarter of all...more

McDermott Will & Schulte

Healthcare Regulatory Check-Up | October 2025 Recap

McDermott Will & Schulte on

This issue of McDermott’s Healthcare Regulatory Check-Up highlights regulatory activity for October 2025, which was relatively quiet due to the federal government shutdown....more

McDermott+

The Ambulatory Specialty Model: Officially coming your way in 2027

McDermott+ on

We are still waiting for the Centers for Medicare & Medicaid Services (CMS) to issue the remaining three calendar year (CY) 2026 Medicare payment rules....more

Latham & Watkins LLP

Healthcare & Life Sciences: Drug Pricing Digest - November 2025 #2

Latham & Watkins LLP on

On November 6, 2025, the Centers for Medicare & Medicaid Services (CMS) issued a press release announcing the voluntary “GENErating cost Reductions for U.S. Medicaid (GENEROUS)” payment model, which will implement most...more

King & Spalding

CMS Issues CY 2026 Medicare Physician Fee Schedule Final Rule

King & Spalding on

On November 5, 2025, CMS issued a final rule implementing changes to the to the Medicare Physician Fee Schedule (PFS), Medicare Shared Savings Program Requirements, and Medicare Prescription Drug Inflation Rebate Program for...more

King & Spalding

2026 Physician Fee Schedule Final Rule Changes to ASP Calculation and Reporting Policies and Other Drug Payment Policies

King & Spalding on

On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) final rule. The final rule,1 which was published in the Federal Register on...more

BakerHostetler

No Opting-Out: Navigating the Uncharted Waters of Medicare’s Ambulatory Specialty Model (ASM)

BakerHostetler on

On Oct. 31, the Centers for Medicare & Medicaid Services (CMS) released the 2026 Medicare Physician Fee Schedule Final Rule, wherein it established the Ambulatory Specialty Model (ASM) – a mandatory alternative payment model...more

Ropes & Gray LLP

Finalized Changes to Medicare Payment Rules: Key Takeaways for Life Sciences Companies

Ropes & Gray LLP on

The Centers for Medicare & Medicaid Services (“CMS”) recently finalized a Medicare payment rule with significant implications for life sciences companies, particularly biotech and pharmaceutical manufacturers....more

Benesch

Dialysis & Nephrology Digest - November 2025

Benesch on

The final rule for the 2026 Medicare Fee Schedule was released by the Centers for Medicare and Medicaid Services (CMS) on October 31, and it appears to have been finalized almost exactly as it was proposed. ...more

McDermott+

What to expect (from CMS) when you’re expecting (an end to the government shutdown)

McDermott+ on

The end of the longest government shutdown in US history is finally here, with the president having signed a continuing resolution (CR) that funds the government through January 30, 2026....more

Troutman Pepper Locke

CY 2026 Medicare Physician Fee Schedule: What Payors and Insurers Need to Know

Troutman Pepper Locke on

On October 31, CMS finalized the CY 2026 Medicare Physician Fee Schedule (PFS) rule (CMS-1832-F), effective January 1, 2026. While primarily directed at Medicare providers, the rule’s changes have clear downstream effects for...more

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