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Clients
Healthcare
Medicare Outpatient/ASC Reimbursement
CMS has issued the CY26 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) final rule. Under the rule, CMS will increase OPPS and ASC payments by an aggregate 2.6% for CY26 relative to CY25 ($8b and $450m increases, respectively). That rate update is comprised of 3.3% market basket update reduced by a proposed...
Clients
Healthcare
ACA Subsidies
It’s been reported that the White House was yesterday planning to release a legislative proposal for addressing the ACA enhanced subsidies (eAPTCs) that expire at the end of this year. The proposal will apparently extend the subsidies for two years, but with modest revisions around eligibility (700% income threshold) and various waste/fraud/abuse...
Clients
Mergers & Acquisitions
Compass/Anywhere
The HSR-waiting period is set to expire on December 1. Our ongoing research continues to suggest a high probability of a second request and a potential basis for litigation, but we still expect the deal will be conditionally cleared. It is evident that the combined company will have a dominant share in certain large MSAs (e.g., San Francisco Bay...
Healthcare
Medicare Dialysis Reimbursement
CMS has issued the CY26 End-Stage Renal Disease (ESRD or dialysis) final rule. Under the rule, CMS will increase the dialysis base rate to $281.71, increasing aggregate payments to dialysis facilities by approximately 2.2% compared to CY25. For hospital-based dialysis facilities, CMS projects an increase in total payments of 1.5%, and for...
Healthcare
Affordable Care Act (eAPTCs)
With the shutdown behind them – and a promised Senate vote on the matter coming up on ~12/12 – lawmakers continue to debate (largely in partisan fashion) whether and how to address the ACA enhanced subsidies that expire at the end of this calendar year. In general, Republicans are increasingly, though not exclusively, pushing for alternatives to...
Clients
Tech / Media / Telecom
Antitrust (Meta, Amazon, Apple)
U.S. District Judge James Boasberg ruled in favor of Meta Platforms Inc., rejecting the Federal Trade Commission's (FTC) antitrust lawsuit that sought to unwind the company's acquisitions of Instagram and WhatsApp.
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