Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”) finalized significant updates to the Hospital Price Transparency regulation for the first time since the rule took effect on January 1, 2021. Many of the changes included in the CY 2024 Medicare OPPS and ASC Final Rule will affect all hospitals and necessitate updates, modifications and in... READ MORE

Hall Render hosted a webinar on July 29, 2021, Surprise Billing and Price Transparency Update. The following includes a selection of audience questions that our attorneys received during and after the webinar. We revised to avoid duplicate responses and to redact any identifying names/information within these questions and answers. The webinar is available on our website for on-demand viewing. Make sure you are also signed up for our alerts to receive information... READ MORE

Beginning January 1, 2021, hospitals across the country must publicly post the prices they charge for items and services, including payer-specific negotiated rates. Despite multiple legal challenges and calls for a delay in enforcement due to COVID-19, the Department of Health and Human Services (“HHS”) has remained unwavering in its commitment to move forward... READ MORE

On November 12, 2020, the United States Department of Health and Human Services (“HHS”), Department of Labor and Department of the Treasury jointly published a final rule requiring health care payors to publicly disclose certain price and cost-sharing information (the “Final Rule”). The Final Rule, which HHS refers to as the “Transparency in Coverage”... READ MORE

House and Senate Panels Announce Surprise Billing Fix On December 8, leaders from the Senate Health, Education, Labor, and Pensions (“HELP”) and House Energy and Commerce committees announced an agreement on surprise billing legislation. The proposal is intended to end surprise billing of patients by creating a new system of dispute resolution that includes... READ MORE

On November 15, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released the final rule on Price Transparency Requirements for Hospitals to Make Standard Charges Public (“Final Rule”) (available here). Despite broad opposition from the industry, CMS finalized the rule largely as proposed. CMS did delay the effective date until January 1, 2021,... READ MORE

CMS Releases Price Transparency Rules On November 15, CMS issued a proposed and final rule, both intended to increase the transparency in pricing for health care providers. One of the rules is the Calendar Year (“CY “) 2020 Outpatient Prospective Payment System (“OPPS”) final rule. The second rule is the Transparency in Coverage proposed... READ MORE

On November 1, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released its final rule for the Calendar Year (“CY”) 2020 Hospital Outpatient Prospective Payment System (“Final Rule”). Among many other changes, CMS finalized three key payment policy updates impacting hospital outpatient departments, including: (1) reducing payments for clinic visits at off-campus provider-based departments (“PBDs”);... READ MORE

On June 24, 2019, the Trump administration changed the game for the health care industry through the release of an executive order on price transparency. Entitled “Improving Price and Quality Transparency in American Healthcare to Put Patients First,” the executive order is aimed primarily at giving patients access to price and quality information about... READ MORE

On January 31, 2019, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a proposed rule that, if finalized, would eliminate Anti-Kickback Statute (“AKS”) safe harbor protection for prescription drug rebates paid by manufacturers to pharmacy benefit managers (“PBMs”), Medicare Part D plans and Medicaid managed care organizations (“Proposed Rule”).... READ MORE