Articles and Blogs

Recent weeks and months have witnessed several Medicaid developments that may significantly impact Medicaid funding across the country. Not all of these developments are related to the Medicaid-related provisions of H.R. 1 (Public Law 119-21 (July 4, 2025), otherwise known as the “One Big Beautiful Bill”). This article summarizes three developments that are unrelated... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) recently issued its calendar year (“CY”) 2026 Outpatient Prospective Payment System (“OPPS”) proposed rule (“Proposed Rule”). The following summarizes several major proposals of the Proposed Rule, and the corresponding fact sheet can be found here. For interested parties and stakeholders, comments should be submitted by September... READ MORE

On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) announced its CY 2026 Physician Fee Schedule (“PFS”) Notice of Proposed Rulemaking (“Proposed Rule”). The Proposed Rule includes information on a new Center for Medicare & Medicaid Innovation (“CMMI”) mandatory payment model called the Ambulatory Specialty Model (“ASM”). If finalized, the new... READ MORE

On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2026 Medicare Physician Fee Schedule (“PFS”) proposed rule. Several of the PFS proposals are related to telehealth, signaling a continued investment and interest in telehealth policies and use post the COVID-19 pandemic. The proposed rule does not address or... READ MORE

On April 30, 2025, the Centers for Medicare and Medicaid Services (“CMS”) released the Fiscal Year 2026 Inpatient Prospective Payment System (“IPPS”) Proposed Rule (the “Proposed Rule”) containing several impactful changes to reimbursement for medical, nursing and allied health education programs at teaching hospitals. These CMS developments include: Proposing to revise the calculations for... READ MORE

In December 2024, the Centers for Medicare & Medicaid Services (“CMS”) made many revisions to its “Guidance for SNF Attachment on Form CMS-855A” (“Guidance”). The Guidance is CMS’s subregulatory advice and FAQs to skilled nursing facilities (“SNFs”) on the completion and submission of the new Form CMS-855A SNF Disclosures Attachment (“SNF Attachment”) for every... READ MORE

On March 7, 2025, the Centers for Medicare & Medicaid Services (“CMS”) posted a memo dated March 10, 2025, that gives nursing homes and surveyors more time to prepare for implementation of new rules and updates to allow surveyors to add extra attention and increase oversight in nursing homes. On November 18, 2024, the... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) has given surveyors new rules and updates to allow surveyors to assess and cite violations of the regulations on resident discharge and transfer. On November 18, 2024, the Quality, Safety & Oversight Group at CMS issued a memorandum entitled “REVISED: Revised Long-Term Care (LTC) Surveyor Guidance: Significant... READ MORE

According to a statement released on the Center for Medicare and Medicaid Services (“CMS”) website, effective February 14, 2025, implementation of the Hospice Special Focus Program for calendar year 2025 has ceased so that CMS may further evaluate the program. Hospice Special Focus Facility Program (“SFP”) The Consolidated Appropriations Act of 2021 called for... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) recently finalized a rule (“Final Rule”) that expands its ability to impose a Provisional Period of Enhanced Oversight (“PPEO”) on providers, including post-acute providers, reactivating their Medicare enrollment. This regulation, authorized under Section 1866(j)(3)(A) of the Social Security Act (“Act”), is designed to strengthen Medicare program... READ MORE