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Are Notice and Comment Rule Making Required Before the Center for Medicare and Medicaid Services Can Adopt Policies Determining How It Will Compute a Component of a Hospital’s Disproportionate Share Reimbursement?

Elliott B. Pollack
January 1, 2019

PREVIEW of United States Supreme Court Cases

Reprinted with permission from the American Bar Association. © 2019

Pullman & Comley attorney Elliott B. Pollack, member of the Health Care practice, authored the case study “Are Notice and Comment Rule Making Required Before the Center for Medicare and Medicaid Services Can Adopt Policies Determining How It Will Compute a Component of a Hospital’s Disproportionate Share Reimbursement?” for the American Bar Association’s 2019 publication PREVIEW of United States Supreme Court Cases.

Elliott’s legal analysis discusses the following court case issue:

Is notice and comment rule making required before the Center for Medicare and Medicaid Services (CMS) can adopt policies determining how it will compute a component of the disproportionate share reimbursement for hospitals that treat many low-income patients?

To read the entire article, please click on the attached PDF.

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