Articles and Blogs

The Centers for Medicare and Medicaid Services (“CMS“) issued a wide-ranging Request for Information (“RFI”) on February 26, which could reshape current program integrity efforts to prevent and detect fraud, waste and abuse in  government health care programs. CMS, under its new Comprehensive Regulations to Uncover Suspicious Healthcare (“CRUSH”) initiative, is seeking stakeholder input... READ MORE

Effective January 1, 2026, the Centers for Medicare & Medicaid Services (“CMS”) implemented significant changes to the accreditation and enrollment framework for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) suppliers through the CY 2026 Home Health Prospective Payment System Final Rule (“Final Rule”). CMS adopted these changes in response to what it describes... READ MORE

On February 2, 2026, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule, effective April 3, 2026, that targets a perceived “loophole” in the current regulatory statistical test applied to State proposals for health care-related tax waivers. The test is intended to make certain that non-uniform or non-broad-based health care-related taxes,... READ MORE

On January 30, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued a proposed rule that would substantially revise portions of the Conditions for Coverage for Organ Procurement Organizations (“OPOs”) (the “Proposed Rule”). According to CMS, the Proposed Rule is characterized as building on changes in the 2020 OPO Conditions for Coverage rule... READ MORE

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