Insights: Policy

Credit Card Fees

The Trump administration this week indicated that it is considering issuing a RFI on credit card late fees. This is seemingly contradictory to its opposition to a Biden-era rule that sought to cap late fees, which was also strongly opposed by the banking industry and Congressional Republicans.

Medicare FFS Reimbursement (OPPS)

As part of the CY27 OPPS rule, CMS proposes a 2.4% increase in the OPD fee schedule. This update reflects a 3.2% hospital market-basket update, reduced by a -0.8% productivity adjustment. CMS estimates total CY27 OPPS payments, including beneficiary cost sharing and estimated changes in enrollment, utilization, and case mix, will be $110.9b, up...

Medicare Site Neutral Payments (OPPS)

CMS’s CY27 OPPS proposed rule would expand site-neutral payment policy to certain imaging-without-contrast services furnished in excepted off-campus provider-based departments (PBDs). CMS proposes to pay the PFS-equivalent rate for imaging-without-contrast services billed with the PO modifier and assigned to APCs 5521-5524 and composite APCs...

340B Drug Discount Program (OPPS)

As part of the CY27 OPPS proposed rule, CMS proposes to pay ASP minus 33.4% for separately payable drugs acquired through the 340B program, while continuing to pay non-340B drugs at ASP plus 6%. CMS also proposes to implement the 340B payment reduction in a budget-neutral manner, which would increase non-drug OPPS service payments by an estimated...

Medicare FFS Reimbursement (Home Health)

CMS proposed the CY27 Home Health Prospective Payment System rule. The proposal would increase aggregate Medicare home health payments by $420m, or 2.4%, in CY27 relative to CY26. The update reflects a +2.1% productivity-adjusted market basket update and a +0.3% increase from the updated fixed-dollar loss ratio. CMS does not propose a new...

Clinical Trials/Pharmaceuticals

HHS launched Operation TrialBlazer, a department-wide effort to accelerate U.S. drug development and counter China’s growing presence in early-stage clinical research. Among other actions, FDA reissued draft guidance clarifying when one adequate and well-controlled trial, plus confirmatory evidence, can satisfy the substantial-evidence standard.