Medicare Skin Substitute (CTP) Update

Medicare reimbursement and coverage policies for cellular and tissue-based products (CTPs), often referred to as skin substitutes, are changing significantly in 2026.  On October 31, 2025, the Center for Medicare and Medicaid Services (CMS) published a final rule announcing that it would be bolstering reimbursement requirements, documentation expectations, and oversight for CTP utilization, effective for calendar year…Read More

Substance Use Disorder Records Update

As of February 16, 2026, all covered entities under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) that receive or maintain substance use disorder (SUD) patient records were required to update their notice of privacy practices (NPP) to include information addressing the modified confidentiality of SUD patient records regulations, known as Part 2. Specifically,…Read More

Uncertainties AHEAD

On November 12, 2025, the State of Maryland and the Centers for Medicare & Medicaid Services (CMS) amended the Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model, which Model is now the basis of the “waiver” that allows Maryland, via the Maryland Health Services Cost Review Commission (HSCRC), to set the rates that Maryland hospitals…Read More

The End of Antitrust Safe Harbors

For nearly three decades, the Department of Justice (DOJ) and Federal Trade Commission (FTC) provided clear guidance for competitor collaborations through a series of policy statements and guidelines. Among the most relied-upon were the 1996 Health Care Anti-trust Policy Statements and the 2000 Antitrust Guidelines for Collaborations Among Competitors. These policies established “safety zones” that…Read More

Medical Debt

Effective October 1, 2025, the Maryland Fair Medical Debt Reporting Act prohibits health care facilities, practitioners, ambulance ser-vices, and entities primarily providing medical services, products, or devices from disclosing medical debt to consumer reporting agencies. Also, contracts for the purchase or collec-tion of medical debt must include a provision prohibiting the disclosure of medical debt…Read More