340B Remedy Rule and Medicare Advantage Rates: Navigating Shifting Payments

By and on May 7, 2024

On April 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the Announcement of Calendar Year (CY) 2025 Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies, otherwise known as the rate announcement. The rate announcement is released annually and includes updates to the methodologies used to calculate MA plan payments, as well as other payment policies that impact Part D. The CY 2025 rate announcement finalizes the policies proposed in CMS’s January 2024 advance notice.

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Emily J. Cook
In today’s complex and fast-changing healthcare regulatory environment, Emily Jane Cook helps healthcare organizations thrive. Innovative start-ups and established market leaders alike turn to Emily for broad-spectrum strategies to fuel new business initiatives and solve their most pressing compliance, transactional, reimbursement and litigation challenges. Emily is a practice area leader for the Healthcare Regulatory & Compliance practice. In addition to Emily’s role as a national authority on the 340B drug pricing program, Emily helps clients navigate the full suite of federal and state regulations that are essential to healthcare operations. She partners with a wide range of organizations, including non-traditional service providers and new market entrants to identify, protect and expand revenue opportunities, including via private-equity-backed ventures. Her comprehensive counsel encompasses evolving issues such as No Surprises Act (NSA) implementation, development of new provider types, Medicare provider-based and co-location rules, and trends in qui tam litigation and government investigations. She works closely with colleagues in McDermott’s transactional, litigation and private equity practices to deliver fully realized solutions for her clients. Read Emily Cook's full bio.


Emily Curran
Emily R. Curran focuses her practice on healthcare regulatory and compliance issues in the managed care space. She counsels both for-profit and non-profit healthcare insurance companies on state and federal policy issues and advises clients on reimbursement issues that come into play when participating in government healthcare programs. Emily also supports the Firm’s transactional work. Read Emily Curran's full bio.

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