Record Recoveries Announced for Fiscal 2025 In January 2026, the Department of Justice announced that False Claims Act settlements and judgments topped $6.8 billion in fiscal year 2025, which ended September 30, 2025. The authors provide an overview of the actions and others where the DOJ has settled and/or recovered damages. On January 16, 2026, the Department of Justice (DOJ) announced that False Claims Act (FCA) settlements and judgments topped $6.8 billion in fiscal year (FY) 2025, which ended September 30, 2025.[1] This figure marks the largest single-year recovery since the FCA was enacted. The government also opened 401 new…
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Advice for Medical and Dental Professionals and Their Advisors This article walks readers through what really matters long before these professionals think about listing their practice for sale. Understanding the “why” behind each step, not just the “what”, is crucial. As one reads through, keep in mind that the information is generalized, not specific to a specific specialty area. It is strongly suggested the dental and medical professionals consult with a trusted professional(s) to provide the smoothest path toward the transition or retirement phase. *Preface: Recently, I have had two medical/dental practice valuation referrals, and two physician-clients ask me for…
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Physician Groups Express Concern Over Efficiency Adjustment and New ASM Model, and Push Towards a Value-Based Model On October 31, 2025, the Centers for Medicare & Medicaid Services released its finalized Medicare Physician Fee Schedule for calendar year 2026. This article discusses the provisions contained in the MPFS final rule, as well as stakeholder reactions. On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) released its finalized Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2026, which “advances primary care management through improved quality measures, reduces waste and unnecessary use of skin substitutes, and introduces a…
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Financial Implications to Hospitals Serving Substantial Percentage of Medicaid & Medicare Patients On November 21, 2025, the Centers for Medicare & Medicaid Services released its Calendar Year 2026 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule, affecting approximately 4,000 hospitals and 6,000 ASCs. The rule finalizes payment updates, policy reforms, and transparency requirements that will impact hospital and ASC operations beginning January 1, 2026. This article discusses the key OPPS changes and updates included in the Final Rule. On November 21, 2025, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY)…
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Increases Payments Earlier this year, the CMS released its proposed MPFS for 2026. In addition to the agency’s suggested increase to physician payments, the proposed rule also announces a new payment model and more telehealth flexibilities. This article summarizes the proposed fee schedule changes. On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) released its proposed Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2026. In addition to the agency’s suggested increase to physician payments, the proposed rule also announces a new payment model and more telehealth flexibilities.[1] According to CMS, the “proposed rule is one…
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Potential Impacts On July 15, 2025, the CMS released the proposed rule for the OPPS and ASC Payment System for calendar year 2026. This article provides an update on the proposed OPPS changes. On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for calendar year (CY) 2026. Among other items, the agency proposes increasing payments to all outpatient providers, eliminating the Inpatient Only (IPO) List, and changing quality reporting programs. For most procedures, the payment rates under the OPPS…
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Healthcare Cost Drivers CMS found that overall healthcare spending growth has decreased slightly but is still elevated compared to pre-pandemic levels and is expected to continue to moderately grow. This article examines the factors underlying the forecasts. On June 25, 2025, the Centers for Medicare and Medicaid Services (CMS) released its forecast on U.S. healthcare spending through 2033. The analysis, published in Health Affairs, estimated healthcare spending growth in 2024 and projected the growth into 2033. CMS found that overall healthcare spending growth has decreased slightly but is still elevated compared to pre-pandemic levels, and is expected to continue to…
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Budget Cuts, Payment Freezes, and Tariffs In an attempt to continue tracking the latest actions of the federal government’s legislative and executive branches affecting the healthcare industry since the last article was released in March, this article summarizes recent events in Washington and the impact of these changes on providers and patients. During the early months of the Republican Party’s government trifecta (controlling the White House, Senate, and House of Representatives), both the Trump Administration and Congress have laid the groundwork for seismic change to the U.S. healthcare industry. In an attempt to continue tracking the latest actions of the…
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In First Month of 2025 In the first month of 2025, hospital revenue and expenses both increased, balancing each other out and resulting in continued steady financial performance for hospitals, according to Kaufman Hall’s January 2025 National Hospital Flash Report. This article reviews the report and the current state of hospital operations. In the first month of 2025, hospital revenue and expenses both increased, balancing each other out and resulting in continued steady financial performance for hospitals, according to Kaufman Hall’s January 2025 National Hospital Flash Report.[1] Revenues grew more quickly in the inpatient setting, as more patients were treated…
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Healthcare Policy Edition During his two months in office, President Trump’s administration has called for significant changes at a fast and furious pace, with several healthcare agencies and programs across the U.S. Department of Health and Human Services (HHS) targeted. To keep up with the latest actions of the legislative and executive branches of the federal government, this article summarizes recent events in Washington and the impact of these changes (both imminent and impending) on providers and patients. During his two months in office, President Donald Trump’s administration has rolled out edicts calling for significant changes at a fast and…
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The Failed “Doc Fix” The Centers for Medicare & Medicaid Services (CMS) released its finalized Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2025. The finalized fee schedule cut payments to physicians, and Congress declined to step in and mitigate the cuts in its last-minute legislation to fund the federal government for another three months. This article discusses the provisions contained in the MPFS final rule and the failed “doc fix” legislation. On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released its finalized Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2025, aiming “to…
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An Overview of the Physician Compensation Surveys Beginning in late May each year, numerous industry normative benchmark physician production and compensation surveys begin publishing the most recent year’s reports. When consulting benchmarking survey data for assessing physician compensation arrangements for FMV, it is important to understand and critically evaluate the quality of the data. This article provides and overview of these surveys. It is the most wonderful time of the year—Survey Season! Beginning in late May each year, numerous industry normative benchmark physician production and compensation surveys begin publishing the most recent year’s reports. These healthcare and specialty specific surveys…
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Ryan LLC v. FTC On August 20, 2024, a Texas federal judge stopped the FTC’s ban on noncompete agreements from going into effect on September 4, 2024. This decision comes after the FTC issued a final rule on April 23, 2024, that bans employers from imposing noncompetes on their employees. The FTC asserted that this exploitative practice kept wages low and suppressed new ideas. While the FTC’s ban will affect all industries—not just healthcare—it comes at a time when healthcare employers across the U.S. are struggling with staffing shortages. This article delves into the decision and ramifications of the decision.…
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Valuation Implications The U.S. government is the largest payor of medical costs, through Medicare and Medicaid, and consequently has a strong influence on reimbursement to healthcare providers. The 2025 proposed fee changes are significant. This article focuses on the proposed fee changes and how these changes may affect valuations of healthcare practices. The U.S. government is the largest payor of medical costs, through Medicare and Medicaid, and consequently has a strong influence on reimbursement to healthcare providers. The prevalence of these public payors in the healthcare marketplace often results in their acting as a price setter and being used as…
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Healthcare Industry and Valuation Implications On June 28, 2024, the U.S. Supreme Court issued a seismic decision in which it explicitly overruled “Chevron deference,” limiting the ability of federal agencies to rely on their own interpretation of the laws they administer. This 6-3 ruling is expected to significantly impact the heavily regulated healthcare industry. The authors share their thoughts on how this decision may impact the healthcare industry and valuations. Chevron deference is a legal test established in the 1984 Supreme Court case, Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc.[1] In this case, the Court ruled that when…
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Valuation-Shopping Investigated On December 19, 2023, the U.S. Department of Justice (DOJ) announced that it had entered into a $345 million settlement with Community Health Network Inc. (CHN), a healthcare network headquartered in Indianapolis, to resolve claims that the hospital violated the False Claims Act (FCA) by knowingly submitting Medicare claims for services which were referred in violation of the Stark Law. This settlement is notable in part because it is the largest Stark-related FCA settlement ever reached by the DOJ. This article discusses this controversy. On December 19, 2023, the U.S. Department of Justice (DOJ) announced that it had…
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Patchwork Approach Continues in Congress On March 9, 2024, President Biden signed into law a $460 billion spending package to continue funding the federal government for the remainder of the 2024 fiscal year. Contained within the spending package was legislation to cut in half the 2024 Medicare physician payment update of approximately -3.4%. This article discusses the payment update, other healthcare provisions contained in the bipartisan spending bills, and responses from stakeholders. On March 9, 2024, President Biden signed into law a $460 billion spending package to continue funding the federal government for the remainder of the 2024 fiscal year.[1]…
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The Impact on Payment Rate Updates, Hospital Price Transparency, Rural Hospital Designation, Drug Pricing, and Intensive Outpatient Program On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) released its finalized Outpatient Prospective Payment System (OPPS) for calendar year (CY) 2024. The finalized payment update increases payments to outpatient facilities and finalizes changes to their hospital price transparency rule, among other provisions. An update to the September 2023 article on the proposed changes to the OPPS, this article discusses the various OPPS changes and updates included in the final rule. On November 2, 2023, the Centers for Medicare…
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Praise and Patient Access Concerns Raised from the Cuts On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) released its finalized Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2024. While the finalized fee schedule cuts payments to physicians, there are a number of other (more positive) provisions in the final rule. An update to the September 2023 article on the proposed changes to the MPFS, this article explores the various changes and updates included in the MPFS final rule. On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) released its finalized Medicare…
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Stakeholders Welcome and Also Dispute Various Changes On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released its proposed Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2024. In addition to the agency’s suggested cut to physician payments, the proposed rule announced changes in policies for the advancement of health equity, as well as the expansion of access to critical behavioral health and oral health services. This article discusses the proposed changes. On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released its proposed Medicare Physician Fee Schedule (MPFS) for calendar year (CY)…