Articles and Blogs

proposed rule

Here’s Price Transparency![1]


Posted on September 13, 2019 in Health Law News

Published by: Hall Render

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

Tags: , , , , , , , , , ,

Stakeholders Asked and CMS Listened – Agency Proposes to Modify Stark Law Advisory Opinion Process


Posted on August 13, 2019 in Health Law News

Published by: Hall Render

In the recently issued Physician Fee Schedule Proposed Rule for Calendar Year 2020, the Centers for Medicare & Medicaid Services (“CMS”) proposed several revisions to its Stark Law advisory opinion process. These proposed revisions follow CMS’s receipt of several stakeholder comments in response to its Request for Information Regarding the Physician Self-Referral Law published... READ MORE

Tags: , , , , , ,

CMS Continues 340B Payment Cuts in 2020 OPPS Proposed Rule Yet Acknowledges Potential for Future Reversal


Posted on August 2, 2019 in Health Law News

Published by: Hall Render

This week, CMS released the 2020 Medicare Hospital Outpatient Prospective Payment System (“OPPS”) and Ambulatory Surgical Center Payment System Proposed Rule (“Proposed Rule”). Among a host of other items, CMS announced its intent to continue paying Average Sales Price (“ASP”) minus 22.5 percent for most drugs acquired under the 340B drug discount program (“340B... READ MORE

Tags: , , , , , ,

CMS Proposes to Eliminate Written Physician Order Requirement as a Condition for Payment for Inpatient Admissions


Posted on May 8, 2018 in Health Law News

Published by: Hall Render

On April 24, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued its proposed rule for the CY 2019 Inpatient Prospective Payment System (“Proposed Rule”). Among many other changes, one very important change stands out in the Proposed Rule, specifically eliminating the requirement that providers record a written inpatient admission order in the medical... READ MORE

Tags: , , , , ,

A Twenty Year Statute of Limitations?


Posted on March 15, 2012 in False Claims Act Defense

Written by: David B. Honig

Last month the Centers for Medicare & Medicaid Services (CMS) published proposed rules for reporting of overpayments. These proposed rules, if adopted and strictly interpreted, could effectively create a twenty-year statute of limitations under the False Claims Act. READ MORE

Tags: , , , , , , , , , , , , , ,