Robert Nauman

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On February 6, 2019, the Department of Health and Human Services (HHS) published a Proposed Rule modifying the Anti-Kickback Statute safe harbor protection with the aim of lowering prescription pharmaceutical product prices and out-of-pocket costs for (primarily Medicare Part D and Medicaid Managed Care Plan) consumers. With the Proposed Rule, HHS hopes to encourage medication manufacturers to pass discounts directly to consumers and develop a transparent framework for the prescription pharmaceutical product market.  A more…
Along with the Federal Association of the Pharmaceutical Industry (BPI), the American Chamber of Commerce in Germany and the Federal Association of German In-house Lawyers (BUJ), we cordially invite you to attend our Life Sciences Day on 20 September 2018 in Frankfurt. The trend for public and private healthcare systems over the past few years has involved strained revenues and declining margins. Finite resources will continue to be taxed with necessary infrastructure projects and an…
Late last month, the Centers for Medicare & Medicaid Services (“CMS”) issued a request for information (“RFI”) seeking input regarding the Medicare physician self-referral law and its implementing regulations (“Stark Law”) and how it may prevent or inhibit care coordination amongst healthcare providers. As part of CMS’s broader “Regulatory Sprint to Coordinated Care” initiative, the RFI’s goals are, in part, to help identify the Stark Law’s regulatory requirements or prohibitions that may impede coordinated care,…
CMS has recently signaled its intention to review the Stark Law and its impact on providers. During a January, 2018 American Hospital Association webinar, CMS Administrator Seema Verma announced the development of an inter-agency group to review the Stark Law in light of provider complaints that the law acts as a barrier to their ability to improve the quality and efficiency of healthcare. While Administrator Verma presented few details, the initiative will involve representatives from CMS,…
On November 13, CMS published the final rule revising the Medicare hospital Outpatient Prospective Payment System for 2018.  Among a number of changes, the final rule dramatically reduces Medicare Part B payments to hospitals for separately payable drugs purchased through the 340B Program.  Currently, Medicare pays hospitals the Average Sales Price (ASP) plus 6% for these drugs regardless of whether the hospital purchased the drug at a discount through the 340B Program.  Under the final…
In recent weeks, we’ve highlighted provisions of the House and Senate tax bills that impact tax-exempt bonds.  However, the bills contain other provisions which may have a significant impact on tax-exempt organizations, including hospitals and other tax-exempt health care providers.  Specifically, provisions in the bills regarding charitable giving, tax-favored financing, governance and compensation, political activity, unrelated business taxable income, and others will be of significant importance to tax-exempt entities should either bill be adopted in current…
Last week, our tax experts summarized certain provisions of the House tax reform bill which would affect the exclusion from gross income of interest on tax-exempt bonds.  This week, we summarize the Senate’s version of the bill which, in contrast, makes no changes to the existing provisions of the Internal Revenue Code that permit the issuance of certain tax-exempt bonds.  This summary may be found on our Public Finance Tax blog, located here.…
The House Committee on Ways and Means has released the first draft of the federal tax reform bill.  This bill, if adopted, would profoundly affect the exclusion from gross income of interest on tax-exempt bonds.  Our public finance and tax experts have prepared a detailed summary for our Public Finance Tax blog.  A link to the post may be found here.…
On July 21, 2017, the Center for Medicare & Medicaid Services (CMS) published a proposed rule that addresses Part B Medicare payments and policies for calendar year (CY) 2018. The major proposed rule is one of several Medicare payment rules for CY 2018 reflecting a broader strategy to relieve regulatory burdens for providers; support the patient-doctor relationship in healthcare; and promote transparency, flexibility and innovation in the delivery of care. The Physician Fee Schedule (PFS)…