Publications by Megan C. Culp

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Proposed OPO Rule Signals Broad Operational and Compliance Changes Across the Donation and Transplantation System

[01/30/26]

From Volume to Value: Reimagining Care through Population Health Services Organizations

[11/24/25]

"Organ Transplant System Reforms Mark Regulatory Overhaul," Law360, October 2025.

[10/29/2025]

OPO Landscape Series: Shutdown Stalls Organ Transplant Oversight

[10/17/25]

Accreditation Update: Changes to the Joint Commission Standards

[07/31/25]

Reforms to Organ Procurement Oversight for Donations After Circulatory Death: What Health Care Providers Need to Know

[07/25/25]

Compliance Deadline July 1, 2025: CMS Hospital and CAH CoP Changes for Emergency Services and Patient Transfers

[07/02/25]

Modernization of the Nation’s Organ Transplant System Continues

[06/10/25]

Emergency Physician Loses Appeal on EMTALA Retaliation Claim

[05/16/25]

HHS and NIH Revise Research Criteria for Organ Transplants Involving Patients with HIV

[01/15/25]

2024 Medicare Physician Fee Schedule Final Rule Makes Changes to Medicare Shared Savings Program

[11/29/23]

CMMI Requests Input on Upcoming Mandatory Episode-Based Payment Model

[07/25/23]

"Tackling Compliance in a Post-PHE Health Care World," Journal of Health Care Compliance/Wolters Kluwer, July-August 2023.

Making Care Primary: CMS Announces a New Primary Care Model 

[06/14/23]

CMS Accepting Applications for Participation in Revamped Medicare Shared Savings Program

[05/23/23]

HHS and CMS Release Guidance on Emergency Reproductive Health Care Under EMTALA

[07/26/22]

REACHing Beyond the Direct Contracting Model: CMS Announces the New ACO REACH Model Application Period

[03/03/22]

Winning the COVID-19 Vaccine Lottery: OIG Weighs in on Anti-Kickback Implications of COVID-19 Vaccine Incentive Programs

[07/07/21]

Medical Groups Should Prepare Now: Changes to the Stark Law’s Group Practice Rules Are Coming

[04/30/21]

The Finish Line Is Here: New Stark and Anti-Kickback Regulations Take Effect Today

[01/19/21]

Defining Opportunity in the Sprint to Value: CMS and OIG Finalize Value-Based Definitions in Connection with New Stark Exceptions and Anti-Kickback Safe Harbors

[01/12/21]

CMS Finalizes New Mandatory Payment Model for ESRD Treatments

[10/19/20]

CMS Finalizes New Mandatory Radiation Oncology Payment Model

[09/29/20]

CMS Announces CHART Model to Transform Rural Health Care

[09/15/20]

CMS Interim Final Rule – Increased Requirements and Enforcement for Data Reporting and Lab Testing

[08/27/20]