Articles and Blogs

In early December, the Centers for Medicare & Medicaid Services (“CMS”) issued its Calendar Year (“CY”) 2021 Medicare Physician Fee Schedule (“MPFS”) final rule (“Final Rule”). Among many other changes, CMS finalized three key payment policy updates impacting non-physician practitioners (“NPPs”), including: (1) clarification that pharmacists may provide services on an incident-to basis; (2) making…Read More

On Friday, December 11, the U.S. Food and Drug Administration issued the first emergency use authorization (“EUA”) for a vaccine for the prevention of coronavirus disease 2019 (“COVID-19”) caused by severe acute respiratory syndrome coronavirus 2 (“SARS-CoV-2”) in individuals 16 years of age and older. The EUA allows the Pfizer-BioNTech COVID-19 Vaccine to be distributed…Read More

On December 14, 2020, the Substance Abuse and Mental Health Services Administration (“SAMHSA”) published a final rule amending the Confidentiality of Substance Use Disorder Patient Records regulations at 42 CFR part 2 (“Part 2”), effective January 13, 2021 (“Final Rule”). This Final Rule clarifies when a court can authorize disclosures of confidential communications made by…Read More

The Centers for Medicare & Medicaid Services (“CMS”) recently announced a new voluntary direct contracting model – the Geographic Direct Contracting Model (the “Model” or “Geo”), which will test whether a geographic-based approach to care delivery and value-based care can improve health outcomes and reduce costs for Medicare beneficiaries across a geographic region. Along with…Read More

The financial difficulties of the COVID-19 pandemic have created disputes between businesses and their insurers around the nation. While it may be tempting to file lawsuits as a creative way to recoup lost revenues, businesses should carefully review their insurance policies before filing suit in order to minimize the risk of losing their limited revenues….Read More

On November 20, 2020, CMS issued its Final Rule (the “Final Rule”) modifying various Stark Law regulations, including those specifically geared toward real estate arrangements. For a general overview of the Final Rule, please see Hall Render’s alert on the subject and our overview webinars on December 1 and December 8. This alert provides a…Read More

Since the onset of the Severe Acute Respiratory Syndrome Coronavirus 2 (“SARS-CoV-2”) pandemic in early 2020, the federal government has been working diligently through Operation Warp Speed to expedite vaccine development for the prevention of Coronavirus Disease 2019 (“COVID-19”). Given the possibility that one or more COVID-19 vaccines may become available before the new year,…Read More

On December 1, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (“Final Rule”) that imposes several modifications to the Medicare Physician Fee Schedule (“MPFS”) for Calendar Year (“CY”) 2021. Notably, the Final Rule will materially increase the Work Relative Value Units (“wRVUs”) that are allocated to several common evaluation and…Read More

On November 20, 2020, the Health and Human Resources Office of Inspector General (“OIG”) issued the long-awaited final rule to overhaul various aspects of the Anti-Kickback Statute and Civil Monetary Penalties Laws (“Final Rule”). The Final Rule issued several new safe harbors and modified existing safe harbors under the Anti-Kickback Statute. As we noted in…Read More