Health Law Alert

On November 15, 2017, the Centers for Medicare and Medicaid Services (“CMS”) published the 2018 Final Medicare Physician Fee Schedule Rule (the “MPFS Final Rule”) in the Federal Register. The MPFS Final Rule addresses changes to the Medicare physician fee schedule and other Medicare Part B payment policies, as well […]

As we jump into 2018, health care institutions who receive TRICARE dollars should assess whether those TRICARE dollars are high enough to require them to prepare Affirmative Action Plans (“AAPs”). If they do, they must get their AAPs in place beginning this year, so that they have the requisite information […]

The Tax Cuts and Jobs Act that was enacted into law on December 22, 2017, introduced a new excise tax on excess compensation (or excess parachute payments) that is paid to “covered employees” by tax-exempt organizations, including government entities with exempt income, beginning with taxable years beginning after December 31, […]

The 340B Program was established by Congress in 1992 and is administered by the Health Resources and Services Administration (HRSA). The Program allows participating hospitals and other health care providers to purchase certain “covered outpatient drugs” from drug manufacturers at discounted prices. Congress’s stated rationale for the 340B Program was […]

For several years, there has been a moratorium on the enforcement of the direct supervision requirement for CAHs and small rural hospitals, with the latest moratorium on enforcement expiring on December 31, 2016. In the 2018 hospital outpatient final rule that was published in the Federal Register on November 13, […]