Changes to NJ Medicaid Pharmacy Reimbursement and 340B

August 9, 2017

New Jersey Medicaid issued two Newsletters describing a change to reimbursement at actual acquisition cost (AAC) for fee-for-service (FFS) Medicaid claims, a new professional fee applicable to retail and long-term-care pharmacy services, and required claim level identification of drugs purchased at the 340B discount (the “Newsletters”).[1] Also, in response to recent communications from certain Medicaid …

CMS Proposes Cut for 340B Hospitals

August 3, 2017

On July 13, 2017, in its Calendar Year (CY) 2018 Hospital Outpatient Prospective Payment System (OPPS) Proposed Rule, the Centers for Medicare & Medicaid Services (CMS) issued a surprise proposal to reduce 340B reimbursement for certain Medicare Part B drugs purchased by 340B-eligible hospitals, hospitals, community mental health centers, and ambulatory surgical centers, starting January …

New State Department of Health Regulations Require a Hospital to Develop Policies and Procedures if it Allows Patients to Bring In and Self-Administer Medical Marijuana

June 23, 2017

New York State Department of Health (DOH) regulations took effect on May 17, 2017 that require hospitals to develop policies and procedures if they allow patients to bring in and self-administer medical marijuana. The DOH regulations require that the hospital’s policies and procedures address security of the medical marijuana product, verification that the patient is …

HRSA Implements New Risk Management Requirements Relating to FTCA Coverage

June 21, 2017

Federally Qualified Health Centers (FQHCs) are required to annually apply for FTCA coverage and submit related documents to the Health Resources and Services Administration (HRSA). In the new application relating to calendar year 2018, which is discussed in Program Assistance Letter (PAL) 2017-03, HRSA has implemented significant new requirements relating to risk management. These new …

CMS Proposes to Cancel Prohibitions Regarding Pre-Dispute Arbitration Agreements

June 14, 2017

On October 4, 2016, the Centers for Medicare & Medicaid Services (“CMS”) adopted a final rule (the “Final Rule”) which revised the requirements for long-term care (LTC) facilities to participate in the Medicare and Medicaid programs. Among other things, the Final Rule prohibited LTC facilities from entering into pre-dispute arbitration agreements with residents and/or their …