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The Centers for Medicare & Medicaid Services (“CMS”) continues to scrutinize beneficiary transparency, medical necessity and data‑driven oversight of hospital billing and utilization. This scrutiny means continued compliance risk for hospitals. Two long‑standing compliance tools remain especially relevant for hospital leadership: the Medicare Outpatient Observation Notice (“MOON”) and the Program for Evaluating Payment Patterns Electronic Report (“PEPPER”). Recent CMS communications reaffirm expectations related to proper MOON delivery and highlight PEPPER as an active monitoring mechanism hospitals should be using…
Continue Reading Medicare Outpatient Observation Notice and PEPPER Reports: Key Compliance Considerations

On December 29, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced the first round of awards under the Rural Health Transformation Program (“RHTP”), a $50 billion, five-year initiative intended to strengthen and modernize health care delivery in rural communities nationwide. All 50 states will receive funding beginning in Federal Fiscal Year (“FFY”) 2026, with first-year awards averaging $200 million per state.

At the same time, CMS formally established the Office of Rural Health Transformation within the Center…
Continue Reading CMS Announces $50 Billion Rural Health Transformation Program Awards to All 50 States

On December 11, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date indefinitely to complete and submit the new Form CMS-855A Skilled Nursing Facility  (“SNF”) Disclosures Attachment for every SNF.

In its Medicare Learning Network, 2025-12-11-MLNC, CMS formally announced that enrolled SNFs should continue collecting data on ownership, managerial, and related party information and submit their revalidation. However, there is no submission deadline until further notice. Guidance for SNF Attachment on Form CMS-855A, updated …
Continue Reading CMS Extends Deadline Indefinitely for Disclosure Requirements for Skilled Nursing Facilities – Provider Enrollment Off-Cycle Revalidations

As a new lawyer handling (what I assumed was) an easy settlement disbursement meeting on a small personal injury case, I vividly recall learning that the client was on Supplemental Security Income (SSI), and then leaving the room to ask one of our firm’s estate planning and elder law attorneys, “Is this going to be an issue?”

Aside from having the good – and increasingly rare – fortune of being part of a general practice firm where I could…
Continue Reading Knowing the Intersection of Settlements and Public Benefits

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On October 31, 2025, the Centers for Medicare & Medicaid Services (“CMS”) issued its calendar year (“CY”) 2026 Medicare Physician Fee Schedule (“MPFS”) final rule (“Final Rule”), announcing finalized policy changes for Medicare payments under the MPFS and other Medicare Part B (“Part B”) issues, effective on or after January 1, 2026. The Final Rule is largely consistent with what was previously shared in CY 2026 proposed rules, with a few modifications as a result of public comment. Several…
Continue Reading Key Highlights from the 2026 Medicare Physician Fee Schedule Final Rule

For many years, alcohol use disorder (AUD) was often viewed as a matter of poor choices or a lack of willpower. Today, medical research makes it clear that this isn’t the case—AUD is a medical condition, not a moral flaw. Like other medical conditions, it can cause difficulty in daily functioning, leading to cravings, compulsive behaviors, and impaired control over drinking. These symptoms can interfere with daily life, relationships, and the ability to work.
What is Alcohol Use Disorder?
Continue Reading Disabled by Alcohol Use Disorder? You Might be Eligible for Short- or Long- Term Disability Benefits

Recent weeks and months have witnessed several Medicaid developments that may significantly impact Medicaid funding across the country. Not all of these developments are related to the Medicaid-related provisions of H.R. 1 (Public Law 119-21 (July 4, 2025), otherwise known as the “One Big Beautiful Bill”). This article summarizes three developments that are unrelated to H.R. 1:

  • U.S. Fourth Circuit Court of Appeals (“Fourth Circuit”) remands intergovernmental transfer (“IGT”) funding case back to the Centers for Medicare & Medicaid

    • …
    Continue Reading Medicaid Developments Unrelated to Recent Congressional Actions

    If you left your job or were let go due to a medical condition some time ago but never filed for short- or long-term disability benefits (S/LTD), the good news is that it might not be too late.

    We regularly hear from people who assumed they missed their chance to file for disability insurance benefits that they had through their last employer. Maybe you thought you’d recover. Maybe you didn’t know you had S/LTD coverage. Maybe you’re only now…
    Continue Reading You Stopped Working Months (or Years) Ago — Can You Still File for Short- and Long-Term Disability?

    Filing a long-term disability (LTD) claim can be an overwhelming process. Even individuals familiar with other related areas of law like Social Security Disability (SSDI) and worker’s compensation are often surprised at how LTD benefits are structured and how many parts of the process work. Insurance carriers rely heavily on policy language and legal standards that favor them, and what may seem straightforward at first often becomes complex once the fine print is applied. 

    At Hawks Quindel, our long-term…
    Continue Reading Five Common Surprises About Long-Term Disability Benefits

    Do I Get Medicare on SSDI? 
    If you are approved for Social Security Disability (SSD) benefits, then you have already proven to the federal government that you suffer from disabling health conditions that likely require extensive medical treatment. Health insurance plays an integral role in ensuring that disabled individuals are able to pay for the care they need. Many individuals on SSD benefits are wondering if they get Medicare as part of their benefits. The answer is often yes,…
    Continue Reading Do I Get Medicare on SSDI?

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    The Centers for Medicare & Medicaid Services (“CMS”) recently issued its calendar year (“CY”) 2026 Outpatient Prospective Payment System (“OPPS”) proposed rule (“Proposed Rule”). The following summarizes several major proposals of the Proposed Rule, and the corresponding fact sheet can be found here. For interested parties and stakeholders, comments should be submitted by September 15, 2025.
    Site-Neutral Payment for Drug Administration Services
    A major component of the Proposed Rule targets excepted off-campus hospital provider-based departments (“HOPDs”), intending to…
    Continue Reading Medicare: Key Highlights of the 2026 OPPS Proposed Rule

    On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) announced its CY 2026 Physician Fee Schedule (“PFS”) Notice of Proposed Rulemaking (“Proposed Rule”). The Proposed Rule includes information on a new Center for Medicare & Medicaid Innovation (“CMMI”) mandatory payment model called the Ambulatory Specialty Model (“ASM”). If finalized, the new mandatory model would begin on January 1, 2027, and run through December 31, 2031.

    The ASM falls within CMMI’s larger framework of activities focusing on…
    Continue Reading What Is ASM? New Ambulatory Specialty Model Proposed by CMMI in CY 2026 Physician Fee Schedule Proposed Rule

    The SSDI eligibility ban in Wisconsin is no more. On July 14th, a federal court issued a preliminary injunction to the Department to stop enforcing the SSDI eligibility ban effective July 20th.
    Note: The Wisconsin Examiner and Fox6 have stories on this court order.
    This order should mean that, as of July 20th, any kind of unemployment claim (initial claim or weekly certification) or any initial determination or appeal tribunal hearing or decision (and any Commission decision over…
    Continue Reading SSDI eligibility ban in Wisconsin no longer enforced

    On July 15, 2025, the Centers for Medicare & Medicaid Services (“CMS”) issued the CY 2026 Hospital Outpatient Prospective Payment System (“OPPS”) and Ambulatory Surgical Center (“ASC”) Payment System proposed rule. The rule, as drafted, proposes updating the payment rates of both OPPS hospital rates and ASC rates by 2.4%, calculated via the respective market basket percentage increases of 3.2% and reduced productivity adjustment of 0.8 percentage points. Regarding the ASC Covered Procedures List (“ASC-CPL”), the CY 2026…
    Continue Reading Medicare’s ASC Proposals for CY 2026

    On July 17, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date to complete and submit the new Form CMS-855A SNF Disclosures Attachment for every Skilled Nursing Facility (“SNF”). 

    In its Medicare Learning Network, 2025-07-17-MLNC, CMS formally announced that enrolled SNFs should collect data on ownership, managerial and related party information and submit their revalidation, and that the new due date is January 1, 2026. 

    Hall Render’s overview of the Medicare disclosure requirements for SNFs…
    Continue Reading CMS Extends (Yet Again!) Deadline for Disclosure Requirements for Skilled Nursing Facilities – Provider Enrollment Off-Cycle Revalidations 

    On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2026 Medicare Physician Fee Schedule (“PFS”) proposed rule. Several of the PFS proposals are related to telehealth, signaling a continued investment and interest in telehealth policies and use post the COVID-19 pandemic. The proposed rule does not address or discuss the continued coverage of telehealth services via the pandemic waiver flexibilities, as this coverage was established through legislation unrelated to CMS’s PFS rulemaking.
    Continue Reading Medicare’s Telehealth Proposals for CY 2026