In the last days of the Biden administration, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued updated compliance program guidance for nursing facilities for the first time in 16 years. The Nursing Facility Industry Segment-Specific Compliance Program Guidance (Program Guidance), while non-binding, provides critical insight into how the…Read More
On September 9, 2024, the Departments of Labor, Health and Human Services, and Treasury issued an updated Mental Health Parity final rule (Final Rule), setting forth new requirements for compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) as amended by the Consolidated Appropriations Act, 2021. MHPAEA requires large group health plans…Read More
Maryland is one of only two states, along with Vermont, launching the first cohort of the new Advancing All-Payer Health Equity Approaches and Development (AHEAD) total cost of care model which will begin next year following a planning period already underway. Maryland has experimented with various unique payment models for decades, most recently the Maryland…Read More
In 2022, the Maryland General Assembly passed The Climate Solutions Now Act (CSNA), which is one of the most ambitious examples of climate change legislation in the country. As a result of the CSNA, the Maryland Department of the Environment (MDE) was tasked with creating new regulations, requiring owners of certain large buildings (covered buildings)…Read More
On October 28, 2024, the federal appellate court for the Fifth Circuit, in Memorial Hermann Accountable Care Organization v. Commissioner, affirmed a United States Tax Court decision, which held that an Accountable Care Organization in the Medicare Shared Saving Program did not meet its burden of showing that it qualified for exemption from federal income tax…Read More
Maryland has become one of the most recent battleground states for litigation regarding the federal 340B drug program initiated by pharmaceutical companies looking to curb the discounts they argue have expanded far beyond the program’s original intent. The 340B Program The 340B program allows hospitals and other covered providers to purchase outpatient drugs from pharmaceutical…Read More
The Centers for Medicare and Medicaid Services (CMS) released the final 2025 Medicare Fee Schedule, which included a reduction in the average payment for providers and modifications to the telehealth services covered by Medicare. Pay Changes The rule, which went into effect January 1, 2025, will result in a net 2.8% decrease in Medicare payments…Read More
In August of 2024, a trial court in California dismissed a price-fixing claim in Verity Health System of California, Inc. v. MultiPlan Corporation. MultiPlan, a provider of health care data analytics, allegedly used its algorithmic repricing tool to set and to lower reimbursement rates health plans paid to out-of-network hospitals. The Facts A bankruptcy…Read More
In the past decade, employers who sponsor pension plans have been subject to class actions brought by their employees, alleging the employers breached their fiduciary duty to pension plan participants by failing to rein in excessive fees. Now, that scrutiny has expanded to include employers who sponsor health plans, and who allegedly have not…Read More
With each passing year, many Maryland physicians are faced with a pressing question:What happens to my license when I retire? If a physician is approaching retirement, there are three options to consider: Inactive Status, Emeritus Status, and Voluntary Non-renewal. Inactive Status One option for physicians retiring in Maryland is to change the status of…Read More