Jeff Murray

CMS aims to decrease burdens and increase innovation in Medicare parts C and D with new April 2018 guidance

By Charlene L. McGinty and Jeff Murray on April 20, 2018 Posted in Uncategorized

In regulations published on April 16, 2018, the Centers for Medicare & Medicaid Services (CMS) issued two new documents containing guidance primarily on the Medicare Advantage (MA) program and on the Medicare prescription drug benefit program. Taken together, these two documents – a finalized regulation outlining policy changes for Contract Year 2019 (Final Rule) and a … Continue Reading

Back to School Rules Recap: Hospital and Physician Cheat Sheet on What CMS Did This Summer

By Kristen McDermott Woodrum, Ernessa McKie and Jeff Murray on August 25, 2017 Posted in Uncategorized

Summer was no vacation for the Centers for Medicare & Medicaid Services (CMS). The agency released a series of significant rules that signal the nature and pace of CMS Medicare payment and policy changes for hospitals and physicians under the Trump administration. For anyone who did take a vacation, this article provides a rulemaking cheat … Continue Reading

Defending Competitive Harm with Efficiencies: A Fire Swamp of Trouble

By Jeff Murray on May 25, 2017 Posted in Uncategorized

The use of efficiencies as a defense remains without a firm footing in law when a transaction has demonstrable and substantial anticompetitive effects. In Rob Reiner’s classic fantasy adventure The Princess Bride, Princess Buttercup and her true love, Westley, stand at the edge of the notoriously deadly Fire Swamp, chased there by enemies and with … Continue Reading

Final Rule Expands OIG Exclusion Authority

By Jeff Murray and Amy Fouts on February 22, 2017 Posted in Uncategorized

On January 12, 2017, less than a week before the official transition from one administration to the next, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued a rule finalizing changes to its most potent compliance tool: exclusion authority. The Affordable Care Act (ACA) significantly expanded the OIG’s permissive … Continue Reading