340B covered entities are facing major changes in the way the discount drug program is reimbursed and administered. On November 1, 2017, CMS made available its 2018 Outpatient Prospective Payment System Final Rule (“Final Rule”).[1] The Final Rule…
On November 1, 2017, CMS published its 2018 Outpatient Prospective Payment System OPPS Final Rule (“Final Rule”).[1] In addition to numerous changes to the 340B Discount Drug Program, the Final Rule finalizes other important rule changes requiring…
In May 2017, the Texas Senate passed Senate Bill 1107,[1] which cleared a path for the State’s various heath care professional boards, including the Texas Medical Board (“TMB”) and Texas State Board of Pharmacy (“TBP”), to offer greater, easier…
The State Medical Board of Ohio recently issued a Frequently Asked Questions Guidance Document (“FAQ”) on Rule 4731-11-09 of the Ohio Administrative Code, which governs when a physician or physician assistant can prescribe medication to a patient…
On September 7, 2017, the Health and Human Services Office of Inspector General (“OIG”) published Opinion 17-05 (“Opinion”) that allowed a retail pharmacy to include Medicare and Medicaid beneficiaries in the pharmacy’s discount benefit program. The…
The Joint Commission is enhancing provider Element of Performance (“EP”) protocols regarding patient medications in response to the nation’s ongoing opioid crisis. Specifically, the Joint Commission has revised its Medication Management (MM) EPs “to…
The Interim Study Committee on Public Health, Behavioral Health, and Human Services (“Committee”) met on September 28, 2017, to discuss the following topics: 1) Potential improvements to the INSPECT program; and 2) the shortage of health care…
Hurricanes Harvey and Irma have devastated our nation in recent weeks and significantly impacted health care facilities in the affected areas. To better address preparedness for disasters such as Hurricanes Harvey and Irma, the Centers for Medicare…
A July 21, 2017 letter from CMS approves Indiana’s State Plan Amendment (“SPA”) 17-0002, which “proposes to bring Indiana into compliance with the reimbursement requirements in the Covered Outpatient Drug final rule with comment.”[1] In review of…
A quick peek at CMS’ FY 2018 budget (and beyond) indicates that CMS is investing heavily in rules enforcement.[1] Encouraged by a Fraud Prevention System return on investment of $11.50 for every $1.00 spent[2], CMS sees enhanced enforcement as a…
As part of the August, 14, 2017 Inpatient Prospective Payment System (“IPPS”) Final Rule[1], the Centers for Medicare and Medicaid (“CMS”) revised the public notice requirements for Medicare provider agreement terminations.
Previously, a Rural…
After months of negotiations, Senate Majority Leader Mitch McConnell failed to find enough Republican support to advance some form of health care reform legislation late last week. Accordingly, the Patient Protection and Affordable Care Act (“ACA”)…
