Policy

Achieved numerous favorable rulings

We have achieved numerous favorable rulings on behalf of major ambulatory surgery centers (ASC) trade associations, e.g., establishing a Medicare ASC benefit, expanding the procedures reimbursed in an ASC, preserving physician ownership of ASCs under the Stark and anti-kickback laws, and mandating the development of a new Medicare payment system for ASCs.

Prevented loss of several millions of dollars for teaching hospital by persuading CMS to modify interpretation of graduate medical education regulations.

Worked to effectively eliminate CMS’ use of LCAs, a draconian coverage policy that was heretofore freely used by CMS to limit utilization of “high-priced” drugs.

Built and implemented a plan that convinced CMS to remove a “fail-first” provision for a specific class of drugs.

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