Today HHS published the Notice of Benefit and Payment Parameters for 2023 proposed rule in the Federal Register. The annual rulemaking details changes to qualified health plans (“QHPs”), QHP issuers, and the ACA’s exchanges including:

Shaping the World of Healthcare Law
Today HHS published the Notice of Benefit and Payment Parameters for 2023 proposed rule in the Federal Register. The annual rulemaking details changes to qualified health plans (“QHPs”), QHP issuers, and the ACA’s exchanges including:
On October 20, 2021, the Centers for Medicare and Medicaid (“CMS”) Innovation Center (“Innovation Center”) published a white paper detailing its vision for the next ten years: a health system that achieves equitable outcomes through high quality, affordable, person-centered care. The white paper first recounts the last ten years of testing and learning that laid the foundation for the Innovation Center’s future strategy. The future strategy is organized around five strategic objectives that will guide the Innovation’s Center’s models and priorities for the next ten years. The five strategic objectives for advancing this systemwide transformation include (1) Drive Accountable Care, (2) Advance Health Equity, (3) Support Innovation, (4) Address Affordability, and (5) Partner to Achieve System Transformation. These strategic objectives aim to guide the Innovation Center’s models which will seek to reduce program costs and improve quality and outcomes for Medicare and Medicaid beneficiaries. Finally, the white paper emphasizes its approach to measuring the progress of each of these objectives and assessing the impact the objectives have on beneficiaries, providers, and the market as a whole.
Continue Reading Centers for Medicare and Medicaid Innovation Center: Equity and Vision
On Thursday, April 8, 2021, the Center for Medicare and Medicaid Innovation (the “Innovation Center”) announced its final list of 53 organizations set to participate in the Global and Professional Direct Contracting (“GPDC”) Model (previously named the Direct Contracting Model for Global and Professional Options). The 53 Direct Contracting Entities (“DCEs”) are participating in the first Performance Year (“PY2021”) of the GPDC Model, which runs from April 1, 2021 through December 31, 2021. The DCEs will serve Medicare fee-for-service (“FFS”) beneficiaries in 38 states as well as in the District of Columbia and Puerto Rico.
Continue Reading CMS Announces Final Organizations for the Global and Professional Direct Contracting Model, Halts Additional Applications and Future Solicitations
On January 13, 2021, Brad Smith, the current (and fourth) director of the Center for Medicare and Medicaid Innovation (the “Center”), published an article[1] in the New England Journal of Medicine in which he evaluates the Center’s performance over its decade-long history against the Center’s stated goals – to decrease health care spending and improve health care quality. Smith describes an underwhelming showing from the Center and puts forward several key lessons from the Center’s past performance as a way to inform and improve future performance.
Continue Reading Evaluation of Innovation Center Models
On June 25, 2020, the Centers for Medicare & Medicaid Services (“CMS”) announced its proposed Home Health Prospective Payment System Rule, for calendar year 2021 (the “Rule”), which aims to increase home health agency Medicare payment rates. This Rule also includes a provision to make permanent the regulatory changes related to telecommunication technologies in providing care under the Medicare home health benefit beyond the expiration of the COVID-19 public health emergency (“PHE”), which is set to time out at the end of July 2020.
Continue Reading CMS Issues Proposed Home Health Agency Rule On Making Certain Telehealth Flexibilities Permanent, Increasing Medicare Payment Rates And Home Infusion Therapy Service Payment Rates For CY 2021
On July 11, 2019, the Centers for Medicare and Medicaid Services (“CMS”) announced a proposed rule for home health agency Medicare reimbursement that would increase payments by an aggregate 1.3% for 2020, amounting to $250 million. In doing so, CMS would begin a transition to payments that are value-based, implementing the Patient-Driven Groupings Model (“PDGM”), an alternate case-mix payment methodology. In the PDGM, home health agencies are paid for 30 rather than 60-day episodes of care, and reimbursement is based on patient characteristics rather than the number of therapy visits provided. In a statement from CMS administrator Seema Verma regarding the proposed rule, she said the PDGM will reward “value over volume.” The proposed changes to reimbursement also include a one-year phasing out of pre-payments for home health services, known as Requests for Anticipated Payment. These proposed changes reflect a significant shift in the manner in which home health agencies historically have been reimbursed.
Continue Reading CMS Proposes New Home Health Agency Rule Including Potential Changes to Reimbursement, Coverage, Quality, and More: CMS Accepting Comments until September 9, 2019
On June 6, 2018, President Trump signed the “John S. McCain III, Daniel K. Akaka, and Samuel R. Johnson VA Maintaining Internal Systems and Strengthening Integrated Networks Act” a.k.a. the VA MISSION Act of 2018 (“VAMA”) into law, a $52 billion reform bill aimed at improving access to, and the quality of, medical services provided to veterans by the Department of Veterans Affairs (the “VA”). We explored the pros and cons associated with VAMA in a June 12, 2018 blog article that we have linked here.
Continue Reading The VA Mission Act: Expanding Access to the VA Telemedicine System
On Wednesday, June 6, 2018, President Trump signed into law the “John S. McCain III, Daniel K. Akaka, and Samuel R. Johnson VA Maintaining Internal Systems and Strengthening Integrated Networks Act” a.k.a. the VA MISSION Act of 2018 (“VAMA”), a $52 billion reform bill aimed at improving access to, and the quality of, medical services provided to veterans by the Department of Veterans Affairs (“VA”).
Continue Reading The VA MISSION Act: Enhancing Healthcare for Veterans