Articles and Blogs

On December 29, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced the first round of awards under the Rural Health Transformation Program (“RHTP”), a $50 billion, five-year initiative intended to strengthen and modernize health care delivery in rural communities nationwide. All 50 states will receive funding beginning in Federal Fiscal Year (“FFY”)... READ MORE

Under the federal Stark Law (the “Stark Law”), hospitals, physician groups, labs and other provider entities may provide non-monetary (i.e., non-cash or cash-equivalent) compensation to physicians up to an aggregate amount of $535 for calendar year 2026. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its... READ MORE

On December 11, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date indefinitely to complete and submit the new Form CMS-855A Skilled Nursing Facility  (“SNF”) Disclosures Attachment for every SNF. In its Medicare Learning Network, 2025-12-11-MLNC, CMS formally announced that enrolled SNFs should continue collecting data on ownership, managerial, and related party... READ MORE

On November 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) issued a letter, which it describes as “preliminary guidance,” concerning two significant restrictions on Medicaid provider taxes set forth in H.R. 1, including: (i) a change in the indirect hold harmless threshold for provider taxes—which, in effect, prohibits states from increasing the... READ MORE

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