Articles and Blogs

On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released its proposed rule for Calendar Year (“CY”) 2020 Hospital Outpatient Prospective Payment System (“Proposed Rule”). Among many other changes, CMS proposed three key payment policy updates impacting hospital outpatient departments, including: (1) lowering the supervision standard for hospital outpatient therapeutic services... READ MORE

On May 6, 2019, the United States District Court in Washington, D.C. issued its opinion on the appropriate remedy to address the invalidated payment cuts set forth in the 2018 and 2019 Outpatient Prospective Payment System final rules (“2018 and 2019 OPPS Rules”) for drugs purchased under the 340B drug discount program (“340B Program”).... READ MORE

January 1, 2019 marked the start of a new data collection period for laboratories pursuant to the Medicare Clinical Diagnostic Laboratory Tests Payment System Final Rule (“CLFS Rule”).¹ The CLFS Rule establishes the Centers for Medicare & Medicaid Services’s (“CMS’s”) new private payor-based rate-setting system for clinical diagnostic laboratory tests (“CDLTs”) paid under the... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) recently issued a proposed rule (“Proposed Rule”) that would require pharmaceutical manufacturers to disclose the list price for a typical course of treatment of prescription drugs and biologics covered by Medicare or Medicaid in direct-to-consumer television advertisements. This policy development comes just two months after the... READ MORE