HRSA Releases Proposed Rule on 340B ADR Program
On August 12, 2016, the Health Resources and Services Administration (HRSA) published a proposed rule: “340B Drug Pricing Program;…
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Yearly Archives
2016
A Mixed Bag – Implied Certification in False Claim Act Cases after…
The United States Supreme Court, in recent decision in Universal Health Services, Inc. v. United States ex rel. Escobar…
Rocky Start to CMS ACO Program
Three of the 21 participants in CMS’ newest accountable care organizations program, the Next Generation ACOs, have withdrawn since…
Weighing in on the Recent Acquittals – Former HHS Inspector General…
Richard Kusserow served as Health and Human Services Inspector General from 1981 to 1992. In this article, he discusses the…
Deep Dive Analysis of 2017 Proposed Physician Fee Schedule
As we previously covered, in July CMS released its annual proposed updates to the Physician Fee Schedule. There are a number of…
Federal Circuit Interprets BPCIA Provision on Notice of Commercial…
In early July 2016, a three-judge panel of the Federal Circuit Court of Appeals issued a unanimous decision in Amgen v. Apotex…
What You Don’t Know About AMP Can Hurt You – Part 2 This is Not Your…
As part of a series on the Average Manufacturer Price (AMP), this month’s article explores the of AMP from the beginning of the…
CMS Seeking Comment on Cardiac Care Model
The Centers for Medicare & Medicaid Services recently announced a new way to pay for the care of patients who have had a heart…
HHS Issues Proposed Rule on Medicare Appeal Backlog
The United States Department of Health and Human Services (HHS) issued a proposed rule intended to address the significant backlog…
Transparency Across the Pond – A Look at Efforts in Germany and the UK
On June 30, 2016, transparency efforts around the world released numbers on financial interactions between industry and…