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Maria Malas

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Maria Malas is an associate in the Governmental Practice in the firm's Washington, D.C. office and a member of the Healthcare Industry 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

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

On November 25, 2025, CMS released the Contract Year (“CY”) 2027 Medicare Advantage (“MA”) and Part D proposed rule (the “Proposed Rule”). The Proposed Rule would make significant changes to the MA and Part D programs, including revising measures under the Star Ratings program, creating a new special enrollment period for enrollees impacted by a provider termination, expanding access to risk adjustment data, relaxing requirements for marketing and communications materials, shortening certain record retention requirements, and easing certain requirements for offering dual eligible special needs plans (“D-SNPs”). In addition, as previewed in the CY2026 final rule and CMS memoranda to plans, the Proposed Rule would rescind several regulatory requirements promulgated under the prior administration. The Proposed Rule also codifies existing CMS guidance in several areas including Part D Redesign. Finally, the Proposed Rule includes several requests for information that are focused on “approaches and opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries, and other interested parties participating in the Medicare program.”Continue Reading Happy Holidays? CMS Contract Year 2027 Medicare Advantage and Part D Proposed Rule Has Winners and Losers

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

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

The Centers for Medicare & Medicaid Services (CMS) recently published the fiscal year (“FY”) 2026 proposed rule for Hospital Inpatient Prospective Payment Systems (IPPS) (the “Proposed Rule”). Comments to the Proposed Rule must be submitted by 5 p.m. EDT on June 10, 2025.Continue Reading CMS Proposes Medicare Payment Policies for Hospital Inpatient Services for Federal Fiscal Year 2026

On April 4, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the contract year (“CY”) 2026 final rule for the Medicare Advantage (“MA”) program, Medicare Prescription Drug Benefit Program (“Part D”), Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (the “Final Rule”). While CMS finalized several proposals of its Proposed Rule, it did not finalize many of its key proposals, including on anti-obesity medication (“AOM”) coverage, enhanced guardrails for artificial intelligence (“AI”), and various health equity related initiatives in MA and Part D.Continue Reading CMS Issues CY 2026 Medicare Advantage and Part D Final Rule

On November 26, 2024, the Centers for Medicare & Medicaid Services (“CMS”) released the contract year 2026 proposed rule for the Medicare Advantage (“MA”) program, Medicare Prescription Drug Benefit Program (“Part D”), Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (the “Proposed Rule”). Likely one of the last significant Medicare reform initiatives of the Biden administration, the Proposed Rule incorporates many of the Administration’s broader policy priorities, focusing on equity, transparency, and modernization in healthcare delivery and oversight.Continue Reading Key Proposals from the CY 2026 Medicare Advantage and Part D Proposed Rule