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On August 27, 2026, the Centers for Medicare & Medicaid Services (“CMS”) announced that the moratorium on accepting Medicare supplier enrollment applications for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) suppliers, which went into effect on February 27, 2026, has expired.

The National Provider Enrollment Contractors are once again accepting initial enrollment applications from DMEPOS suppliers.
Practical Takeaways

  • DMEPOS suppliers seeking to submit applications to CMS should submit as soon as possible before the bidding window opens for

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Continue Reading DMEPOS Supplier Enrollment Opens as Medicare Moratorium Expires

On August 4, 2026, the Centers for Medicare & Medicaid Services (“CMS”) published the Fiscal Year (“FY”) 2027 Inpatient Prospective Payment System (“IPPS”) Final Rule (the “Final Rule”), which can be found here. The Final Rule is effective October 1, 2026, and includes several updates affecting Graduate Medical Education (“GME”) and Nursing and Allied Health (“NAH”) education programs under Medicare. These updates include: (i) modifications to the criteria for determining whether a residency program qualifies as a “new…
Continue Reading CMS Changes to Graduate Medical Education in 2027 IPPS Final Rule

On August 4, 2026, the United States Department of Justice (“DOJ”) on behalf of the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services announced it had entered into a $14.1M settlement with Complete Health Partners Holdings (“Complete Health”), a Florida management services organization (“MSO”), to resolve allegations that Complete Health submitted false risk adjustment scores in violation of the False Claims Act. As an MSO, Complete Health provides non-clinical administrative and operational support…
Continue Reading Compliance Program Lessons from the Complete Health Settlement

Receiving a long-term disability (LTD) denial can feel overwhelming. After months of medical appointments, paperwork, and waiting for a decision, many people are left wondering what to do next and whether they should appeal on their own or hire a lawyer. The honest answer is: it depends.
Whether you should appeal on your own depends on why your claim was denied, what evidence is already in your file, and what opportunities you have to strengthen your case before your…
Continue Reading Should I Appeal my Long-Term Disability Denial on My Own or Hire a Lawyer?

On July 30, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued its final rule updating Medicare payment policies and rates for skilled nursing facilities (“SNFs”) under the Skilled Nursing Facility Prospective Payment System (“SNF PPS”) for federal fiscal year (“FY”) 2027. The final rule also includes significant revisions to the Skilled Nursing Facility Quality Reporting Program (“SNF QRP”) and the Skilled Nursing Facility Value-Based Purchasing (“SNF VBP”) Program. The rule becomes effective October 1, 2026.

While the…
Continue Reading Skilled Nursing Facility Update: CMS Finalizes FY 2027 SNF PPS Rule: Payment Increase, QRP Reforms and Expanded MDS Reporting Requirements

On August 5, 2026, the U.S. Department of Health and Human Services (“HHS”) announced that the Centers for Medicare & Medicaid Services (“CMS”) has begun the decertification process for Network for Hope, the organ procurement organization (“OPO”) with a service area that includes Kentucky and portions of Indiana, Ohio and West Virginia. According to HHS, the action follows multiple federal reviews that identified ongoing patient safety concerns and determined that the OPO had not demonstrated sufficient improvement despite corrective…
Continue Reading HHS Begins Decertification of Network for Hope, Kentucky’s Organ Procurement Organization

The Indiana Health Coverage Programs announced that it has received approval from the Centers for Medicare & Medicaid Services (“CMS”) to implement a statewide provider certification and enrollment moratorium for numerous Home- and Community-Based Services (“HCBS”) 1915(c) waiver providers. The moratorium becomes effective August 1, 2026, and initially will remain in effect for six months, although Indiana may seek six-month extensions.

Unlike many Medicaid enrollment moratoria that apply to a single provider type or geographic area, Indiana’s action applies…
Continue Reading Indiana HCBS Update: Indiana Imposes Statewide HCBS Provider Certification and Enrollment Moratorium

July 23, 2026

When applying for Wisconsin Medicaid long-term care programs, financial eligibility is only part of the process. Individuals must also demonstrate that they meet the required level of care through what is known as the functional screen test.

The functional screen is a standardized assessment used in Wisconsin to determine whether an individual qualifies for Medicaid-funded long-term care services. Rather than focusing on finances, the screening evaluates a person’s ability to safely care for themselves and function

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Continue Reading Understanding the Functional Screen Test

On January 1, 2027, mandatory downside financial risk under the Centers for Medicare & Medicaid Services’ (“CMS”) Transforming Episode Accountability Model (“TEAM”) will begin for most participating hospitals. TEAM is a mandatory, episode-based alternative payment model that took effect on January 1, 2026, and will end on December 31, 2030. Most hospitals located in any of the 188 Core-Based Statistical Areas (“CBSAs”) selected by CMS were required to participate. Calendar Year 2026 is Performance Year One (“PY1”) and is…
Continue Reading Turning TEAM Risk into Opportunity: The Case for a Value-Based Enterprise

Two female doctors chatting while walking upstairs in a hospital
Two female doctors, wearing blue scrubs, are walking up a staircase in a hospital, chatting together. They appear to be in a good mood. There are other medical professionals walking in the background.

For years, Wisconsin has been among a shrinking group of states that require advanced practice nurses to maintain a collaborative agreement with a physician or dentist in order to practice. That is about to change. On September 1, 2026, the APRN Modernization Act (Act 17) takes effect, moving Wisconsin from a system that certifies advanced practice nurse prescribers (APNPs) to one that licenses advanced practice registered nurses (APRNs) and, for qualifying nurses, permits independent practice for the first time.
Continue Reading Wisconsin’s APRN Modernization Act – New Emergency Rules Chart the Path to Independent Practice

The Centers for Medicare & Medicaid Services (“CMS”) has announced the nationwide implementation of a new Risk-Based Survey (“RBS”) process for qualifying nursing homes beginning September 8, 2026. CMS Memorandum QSO-26-14-NH explains that the RBS is intended to allow State Survey Agencies (“SAs”) to use fewer survey resources at higher-performing facilities and redirect resources toward complaint investigations and facilities where residents may face greater risk of harm.

CMS estimates that approximately 12% of nursing homes nationwide currently qualify. Qualifying…
Continue Reading Skilled Nursing Update: CMS Implements Nationwide Risk-Based Surveys For Higher-Performing Skilled Nursing Facilities

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By | Elder Law
July 8, 2026

One of the most common concerns families face when discussing long-term care is cost. Whether care is provided at home, in an assisted living facility, or in a nursing home, long-term care expenses can become significant very quickly.

In Wisconsin, nursing home care can cost thousands of dollars each month, and even part-time in-home assistance may create substantial financial strain over time. Because Medicare coverage for long-term care is…
Continue Reading How Much Does Long-Term Care Cost and How Do I Pay for It?

The results of the 2026 National Health Care Fraud Takedown (the “Takedown”) were announced on June 23, 2026; the Department of Justice (“DOJ”) charged 455 individuals in connection with alleged health care fraud schemes involving over $6.5 billion in false claims. Ninety of the charged individuals were physicians or other medical professionals.

The Takedown, dating back to 2007, is conducted annually by DOJ, the Department of Health and Human Services Office of Inspector General (“HHS-OIG”), the Federal Bureau…
Continue Reading DOJ’s Continued Focus on Medicare and Medicaid Fraud Produces $6.5 Billion Health Care Fraud Takedown

Earlier this year, Congress enacted Section 6225 of the Consolidated Appropriations Act, 2026 (“CAA”), establishing a new Medicare condition of payment for off-campus hospital outpatient departments beginning January 1, 2028. As discussed in our prior alerts (here and here), the statute generally prohibits Medicare payment for services furnished by an off-campus hospital outpatient department unless the department bills under a separate National Provider Identifier (“NPI”) assigned to that off-campus department, the hospital submits an initial provider-based attestation…
Continue Reading Mandatory Provider-Based Attestations Are Taking Shape: CMS Releases Proposed Implementation Framework

Buried in the July 1, 2026, proposed rule for the Home Health Prospective Payment System (“Proposed Rule”), the Centers for Medicare & Medicaid Services (“CMS”) proposed changes to provider enrollment and a provider’s ability to obtain and maintain Medicare billing privileges. Notably, the changes to provider enrollment regulations at 42 CFR Part 424, Subpart P affect every Medicare-enrolled provider and supplier.
Revocation and Denial Updates Applicable to All Medicare Providers and Suppliers
CMS is proposing several provider enrollment provisions…
Continue Reading CMS Proposes Significant Changes Impacting Provider Enrollment Including Provider/Supplier Billing Privileges

Multiple Sclerosis (MS) is a chronic medical condition that is characterized by brain fog, fatigue, muscle weakness, and many other debilitating symptoms that limit a person’s ability to function on a daily basis1. For many people living with MS, the hardest part can often be the uncertainty that follows. While symptoms can vary from person to person, these symptoms can often make sustained employment difficult. When that happens, employer-provided short- and long-term disability benefits plans may be necessary to…
Continue Reading Multiple Sclerosis and the Difficult Road to Long-Term Disability Benefits