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HHS withdraws 340B Mega Guidance

On January 30, 2017, the United States Department of Health and Human Services (HHS) decided to withdraw "Mega Guidance" related to the 340B drug discount program. This withdrawal comes after the Trump administration put a freeze on new regulations. The 340B drug discount program is a United States federal government program that requires drug manufacturers participating in Medicaid to provide outpatient drugs to eligible health care organizations, known as covered...

Opioid Prescribing and the Importance of Knowing Naloxone Dispensing Laws

In 2016, the Centers for Disease Control and Prevention (CDC) announced that the United States is in the midst of an opioid overdose epidemic. Opioids include both prescription drugs, such as Hydrocodone, Morphine, Percocet, and Oxycontin, and illegal drugs such as, Heroin. Both prescription opioids and heroin killed more than 33,000 people in 2015, which was more than any year on record. Although street-drugs are considered by the general public...

Overcoming Hurdles to Achieve Physician In-Office Dispensing of Drug Therapy and Physician Owned Pharmacies

With the advent of value-based healthcare reimbursement becoming more of a reality each and every day for healthcare providers, physicians are frequently looking for new and innovative ways to maximize quality in the services they provide each of their patients. One of the ways physicians aim to do this is through in-office physician dispensing of prescription medications, or physician owned pharmacies. In-office physician dispensing or physician owned pharmacies can make...

What Providers Need to Know about MACRA’s Value-Based Tracks: Merit-based Incentive Payment Systems (MIPs) and Alternative Payment Models (APMs)

Over the past few years, the Centers for Medicare & Medicaid Services (CMS) has been looking to find new and innovative ways to reimburse providers who provide care to Medicare beneficiaries. In April 2015, Medicare Access and CHIP Reauthorization Act (MACRA), a new and alternative payment method law that revamps fee-for-service payment, was signed in to law by President Obama. MACRA is proposed to change the way Medicare pays clinicians and...

The Centers for Medicare & Medicaid Services Revises Self-Disclosure Program

The federal law regulating physician referrals of Medicare or Medicaid patients to entities that the the physician or the physician's immediate family member has a financial interest, commonly referred to as the "Stark Law," can have dramatic consequences if violated. The healthcare community has witnessed a dramatic increase in the government’s enforcement of the Stark Law, as well as the federal anti-kickback statute, since the passage of the Affordable Care...