Articles and Blogs

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

On August 28, 2024, the Centers for Medicare & Medicaid Services (“CMS”) published the Fiscal Year 2025 Inpatient Prospective Payment System (“IPPS”) Final Rule (“Final Rule”), which can be found here (Hall Render’s alert on the 2025 IPPS Final Rule can be found here). Among other things, the Final Rule finalized updates to Graduate... READ MORE

On May 10, 2022, CMS published its proposed revisions to the Inpatient Prospective Payment System for 2023. CMS proposed two changes that would affect reimbursement for graduate medical education (“GME”) programs at teaching hospitals. First, CMS proposed to update the way that it calculates direct GME (“DGME”) payments for fellows in some training programs,... READ MORE

Recent regulations from the Centers for Medicare & Medicaid Services (“CMS”) based on the GME changes in the Consolidated Appropriations Act, 2021 (“CAA”) create new funding opportunities for many teaching hospitals. Opportunities are available for hospitals in the following categories: CMS will award 1,000 new FTE cap slots over the next five years. CMS... READ MORE

This client alert is Part 5 of our series providing insight into Medicare graduate medical education (“GME”) reimbursement changes that occurred in 2021. Part 1, which addressed resident moonlighting and redocumentation requirements, is available here. Part 2, which addressed billing requirements for physicians at teaching hospitals (the “PATH” rules) and the rules regarding cap... READ MORE

The Consolidated Appropriations Act (“Appropriations Act”) that Congress passed in late December 2020 contained a number of provisions that will be of benefit to teaching hospitals. This article is Part 3 of our series providing insight into these CMS changes and more recent statutory changes. Part 1, which addresses resident moonlighting and redocumentation requirements,... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) published numerous updates to its rules for graduate medical education in 2020, many of which take effect in the early part of 2021. This client alert is Part 2 of our series providing insight into these CMS changes and more recent statutory changes. Part 1, which... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) published numerous updates to its rules for graduate medical education in 2020, many of which take effect in the early part of 2021. This client alert is part one of our three-part series giving insight into these CMS changes and more recent statutory changes. Moonlighting Rule... READ MORE

CMS finalized a proposal to allow the temporary transfer of Medicare graduate medical education (“GME”) full-time equivalent (“FTE”) cap slots from teaching hospitals that terminate their Medicare provider agreement or close a residency program to hospitals that continue training their departing residents or fellows. CMS made relatively few changes to the rule that it... READ MORE

Mergers and acquisitions in the health care industry present unique challenges that are not often present when undertaking transactions in other industries. Because of health care’s highly regulated nature, parties may falter if a health care transaction is not reviewed and negotiated carefully with respect to all of the components of health care regulation.... READ MORE