On Thursday, July 13, 2023, the Centers for Medicaid & Medicaid Services (CMS) released the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) Proposed Rule (CY 2024 PFS Proposed Rule), which proposes policy changes to the PFS and other Medicare Part B issues, effective on or after January 1, 2024.  As explained in our article, the CY 2024 PFS Proposed Rule includes several policy proposals that would change coverage of and access to telehealth services for Medicare beneficiaries.  Among other policy proposals, the CY 2024 PFS Proposed Rule would:

  • Implement the telehealth provisions in the Consolidated Appropriations Act, 2023;
  • Update the process for adding, removing, or changing services on the Medicare Telehealth Services List;
  • Change the payment methodology for Medicare telehealth services furnished to beneficiaries at home; and
  • Extend direct supervision via use of two-way audio/video communications technology.

Read the full article to learn more about CMS’ proposed changes to Medicare telehealth policy.

Photo of Rujul Desai Rujul Desai

Rujul Desai advises clients on drug pricing, market access, reimbursement, strategic contracting, and regulatory solutions for drugs, biologicals, devices, and diagnostics. He brings deep experience with biopharma, specialty pharmacy, and pharmacy benefit management (PBM) companies.

Rujul has held a number of leadership roles…

Rujul Desai advises clients on drug pricing, market access, reimbursement, strategic contracting, and regulatory solutions for drugs, biologicals, devices, and diagnostics. He brings deep experience with biopharma, specialty pharmacy, and pharmacy benefit management (PBM) companies.

Rujul has held a number of leadership roles in the biopharma, PBM, and specialty pharmacy industry, including with CVS Caremark, UCB, and most recently as Vice President at Avalere Health. He has led engagements across a wide range of U.S. and global market access and reimbursement issues, including optimizing new product launches, pricing, PBM and payer formulary access, value-based contracting, distribution network design, patient access and hub services, affordability programs, e-prescribing, digital health, and the use of health economic data and modeling.

Rujul is an author of the U.S. chapter of a global treatise on drug pricing and reimbursement.

Rujul was a Captain in the Medical Services Corps of the U.S. Army Reserves, and served in active duty in Iraq.

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Photo of Anna D. Kraus Anna D. Kraus

Anna Durand Kraus advises on issues relating to the complex array of laws governing the health care industry. Her background as Deputy General Counsel to the U.S. Department of Health and Human Services (“HHS”) gives her broad experience with, and valuable insight into…

Anna Durand Kraus advises on issues relating to the complex array of laws governing the health care industry. Her background as Deputy General Counsel to the U.S. Department of Health and Human Services (“HHS”) gives her broad experience with, and valuable insight into, the programs and issues within the purview of HHS, including Medicare, Medicaid, fraud and abuse, and HIPAA privacy and security. Anna is co-chair of the firm’s Health Care Industry practice group.

Anna regularly advises clients on Medicare reimbursement matters, particularly those arising under Part B and the Part D prescription drug benefit. She also has extensive experience with the Medicaid Drug Rebate program. She assists numerous pharmaceutical and device manufacturers, health care providers, pharmacy benefit managers, and other health care industry stakeholders to navigate the challenges and opportunities presented by the Affordable Care Act.

Anna is a trusted adviser on health information privacy, security and breach notification issues, including those arising under the Health Insurance Portability and Accountability Act (“HIPAA”) and the Health Information Technology for Economic and Clinical Health (“HITECH”) Act. Her background in this area dates back to the issuance of the original HIPAA privacy regulations.

Anna’s clients depend on her to guide them through compliance with the Anti-Kickback statute, the Stark regulations, and other laws preventing fraud and abuse in the health care industry. Her deep knowledge of these laws has made her an important component of the firm’s representation of pharmaceutical companies and health care organizations under federal investigation or facing allegations under the False Claims Act. In addition, clients contemplating acquisitions in the health care sector rely on her to guide due diligence efforts.

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Photo of Chelsea Segal Chelsea Segal

Chelsea Segal’s health care practice focuses on regulatory, compliance, and business issues related to telehealth and telemedicine, digital health, pricing and reimbursement, and fraud and abuse. On the life sciences side, Chelsea advises pharmaceutical clients on issues surrounding the regulation of drugs and…

Chelsea Segal’s health care practice focuses on regulatory, compliance, and business issues related to telehealth and telemedicine, digital health, pricing and reimbursement, and fraud and abuse. On the life sciences side, Chelsea advises pharmaceutical clients on issues surrounding the regulation of drugs and biologics by the U.S. Food and Drug Administration (FDA), including product approval, advertising and promotion, and communications with payers.

Chelsea routinely advises on administrative and legislative policy developments related to telehealth and telemedicine as well as FDA regulatory issues. She also provides support to clients engaged in life sciences mergers and acquisitions and other commercial transactions, including due diligence.

Chelsea also maintains an active pro bono practice at Covington, with a particular focus on reproductive rights.

Chelsea is an author of a chapter on manufacturer communications with payers in the American Health Law Association treatise, Pricing, Market Access, and Reimbursement Principles: Drugs, Biologicals and Medical Devices.

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