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Margia Corner

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Margia Corner is a partner in the Governmental Practice in the firm's San Francisco and Washington, D.C. offices and a member of the firm’s Healthcare Team.

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The Centers for Medicare & Medicare Services’ (“CMS”) Innovation Center will begin accepting applications on January 12 for the recently announced Advancing Chronic Care with Effective, Scalable Solutions (“ACCESS”) Model—a nationwide voluntary alternative payment model for Medicare Part B commencing July 5, 2026 that will run for 10 years and focus on chronic conditions affecting over two-thirds of Medicare beneficiaries such as diabetes, high blood pressure, and depression.[1]­ Health care organizations, such as physician groups, must be enrolled in Medicare Part B to be eligible to participate as an ACCESS “Participant” and must take responsibility for delivering integrated, coordinated services—in person, virtually, asynchronously, or through other technology-enabled modalities—to Medicare patients to manage those patients’ chronic conditions for a twelve-month period. Participants must designate a Medicare-enrolled Medical Director to oversee care quality and compliance. The Model will initially encompass four non-mutually-exclusive clinical tracks corresponding to common chronic conditions[2]:Continue Reading Application Window Opens Soon for CMS ACCESS Model Expanding Technology-Supported Care Options for Traditional Medicare

Providers and suppliers participating in the Medicare program should take note of new requirements and compliance considerations related to Medicare enrollment, information updates, changes of ownership, and increased risk for revocation, set to take effect on January 1, 2026. The most consequential changes are found in the CY 2026 Home Health Agency Prospective Payment System (HH PPS) final rule (“Final Rule”), which was published on December 2, 2025.[1] In this Final Rule, Centers for Medicare & Medicaid Services (“CMS”) finalized substantial expansions to its authority to retroactively revoke enrollment for all types of Medicare providers and suppliers, including hospitals, hospices, and home health agencies to physician practice groups and DMEPOS suppliers related to Medicare enrollment and compliance deficiencies. CMS also shortened reporting deadlines and broadened its ability to suspend enrollment during investigations. These changes apply across all Medicare provider and supplier types and significantly tighten compliance expectations. The Final Rule further introduces targeted revisions for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) suppliers, including expansion of the Medicare 36-month rule and increased survey and reaccreditation frequency.Continue Reading Medicare’s New Enrollment, Reporting and Oversight Landscape: What Providers and Suppliers Need to Know for 2026

The Centers for Medicare & Medicaid Services (“CMS”) final rule for Medicare payment for services provided in hospital outpatient departments (paid under the Outpatient Prospective Payment System or “OPPS”) and ambulatory surgery centers (“ASCs”) during calendar year (“CY”) 2026 (the “Final Rule”) largely adopts CMS’ proposed changes to advance President Trump’s policy directives to:Continue Reading CMS Finalizes Medicare Payment Policies for Hospital Outpatient and Ambulatory Surgery Center Services

The Centers for Medicare and Medicaid Services (“CMS”) recently announced the first six participating states in the Wasteful and Inappropriate Service Reduction (“WISeR”) Model that will begin on January 1, 2026: Arizona, New Jersey, Ohio, Oklahoma, Texas, and Washington.[1] As its hallmark objective, the Model aims to refine prior authorization processes for traditional fee-for-service Medicare through the use of enhanced technologies, such as artificial intelligence (“AI”), to reduce the performance of, and payment for, services that are deemed to be “low value.” Model participants will receive a percentage of the savings associated with avoided “wasteful, inappropriate care” as a result of their reviews.Continue Reading New WISeR Model Aims to Leverage AI Technology to Reduce Costs and Inefficiencies

The Centers for Medicare & Medicaid Services (“CMS”) recently finalized a rule establishing the new Ambulatory Specialty Model (“ASM”)— a mandatory value-based payment model that could apply to nearly one-quarter of all physicians in select specialties starting January 1, 2027. The ASM applies to physicians providing services to address two high-expenditure chronic conditions among Medicare patients: heart failure (cardiology) and low-back pain (pain management, interventional pain, neurosurgery, orthopedic surgery, and physical medicine and rehabilitation). Participation will be mandatory for eligible clinicians practicing in geographic areas selected by CMS that will likely encompass approximately one-quarter of U.S. Core-Based Statistical Areas (“CBSAs”) or metropolitan divisions nationwide. Published in connection with the Calendar Year (“CY”) 2026 Medicare Physician Fee Schedule (“PFS”), this alternative payment model represents a significant step in CMS’s transition toward specialty-specific accountability for cost, quality, and care coordination in ambulatory care. The model has significant implications for specialty practices, particularly those participating in or aspiring to join Accountable Care Organizations (“ACOs”). Additionally, the ASM will leverage components of the existing Merit-based Incentive Payment System (“MIPS”)/Medicare Value Pathways (“MVPs”) frameworks. For clinicians subject to MIPS/MVP, this model introduces a revised approach to performance scoring under a familiar framework.Continue Reading CMS Finalizes Mandatory Ambulatory Specialty Model for Cardiology and Low-Back Pain

On September 15, 2025, the Centers for Medicare & Medicaid Services (“CMS”) published a highly anticipated Notice of Funding Opportunity (“NOFO”) announcement (the “Announcement”) to implement the Rural Health Transformation (“RHT”) Program (“RHTP”) established by the One Big Beautiful Bill Act (“OBBBA”) to allocate $50 billion over a five-year period (fiscal years 2026 to 2030) to approved states that meet applicable statutory and CMS requirements. The Announcement provides new insights to states and other stakeholders regarding how CMS will evaluate applications from states for RHTP funding, as well as detailed application instructions, eligibility standards, scoring methodology, strategic goals, policy priorities, and examples of strategic initiatives that align with the goals of the RHTP.Continue Reading CMS Announces Application Details for Rural Health Transformation Program

Comments are due in less than a month on the Centers for Medicare & Medicaid Services (“CMS”) proposals to make significant structural reforms to Medicare’s Competitive Bidding Program (“CBP”) for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) and DMEPOS accreditation requirements as well as major revisions to the Medicare provider enrollment rules for all Medicare provider and supplier types (the “Proposed Rule”). Comments must be submitted no later than 5 p.m. EDT on September 2, 2025.Continue Reading Major Policy Changes Proposed for Medicare Payment, Accreditation, and Prior Authorization for DME Suppliers

The Centers for Medicare & Medicaid Services recently published the calendar year (“CY”) 2026 proposed rule for Medicare payment for services provided in hospital outpatient departments under the Outpatient Prospective Payment System (“OPPS”) and services provided in ambulatory surgery centers (“ASCs”) (“the Proposed Rule”). Comments are due by September 15, 2025.Continue Reading Proposed Medicare Payment Policies for Hospital Outpatient and Ambulatory Surgery Center Services

Among the many sweeping changes to the Medicaid program included in the One Big Beautiful Bill Act (“OBBBA”), Congress established new statutory caps on state-directed payments (“SDPs”) in Medicaid managed care. SDPs have long served as a critical mechanism for states pursuing value-based payment (“VBP”) reforms, addressing network adequacy, and advancing health equity for underserved populations. OBBBA imposes explicit Medicare-based caps on new SDPs, time-limited exceptions for certain SDPs that were approved or in development on or before July 4, 2025, and a phased transition to new payment caps beginning January 1, 2028, that will reshape state payment policy tools to drive VBP, narrow disparities, and close gaps in access.[1] State Medicaid agencies, healthcare providers, patient advocacy groups, and other stakeholders should prepare to weigh in as the Centers for Medicare and Medicaid Services (“CMS”) proposes regulations to implement these changes in the coming months.Continue Reading State-Directed Payments, Value-Based Care, and the “One Big Beautiful” Bill: A Comprehensive Analysis

A federal judge in D.C. recently ruled in favor of the U.S. Health Resources and Services Administration (“HRSA”), an administrative agency under the U.S. Department of Health and Human Services (“HHS”), by finding that drug manufacturers must obtain pre-approval from HRSA before implementing rebate models under the 340B Program. Specifically, U.S. District Judge Friedrich (“Friedrich”) found that HHS and HRSA did not exceed their authority when they required Eli Lilly & Co., Bristol Myers Squibb Co., Sanofi-Aventis U.S. LLC, Novartis Pharmaceuticals Corp. (“Novartis”) and Kalderos Inc., a health care tech company (together, the “Companies”) to seek pre-approval of the rebate plans they offered.[i]Continue Reading Federal District Court Upholds Authority of HHS to Pre-Approve 340B Rebate Programs; HRSA Submits Proposed 340B Rebate Guidance

On May 15, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule, entitled “Preserving Medicaid Funding for Vulnerable Populations – Closing a Health Care-Related Tax Loophole” to address a financing loophole that allows states to shift more Medicaid costs to the federal government than intended (the “Proposed Rule”). If finalized as proposed, states that received CMS-approved waivers for state healthcare-related taxes within the last year—including California, New York, Michigan, and Massachusetts—would be required to modify or eliminate those state taxes immediately or risk losing federal matching funds for expenditures paid using those tax revenues. Comments from stakeholders are due by July 14, 2025.Continue Reading Proposed Rule on Medicaid Tax Waivers: CMS Moves to Close a Loophole Shifting Costs to the Federal Government