Firm Wire items are announcements made by the firms themselves. The desk confirms that the announcement was published and reproduces its factual content. It does not verify the claims in it, and publication is not an endorsement.
Sidley says it published an analysis of HHS exclusion authority delegated to CMS
Sidley said it published an analysis of the HHS secretary’s extension of exclusion authority to the Centers for Medicare & Medicaid Services. The firm’s article examines the relationship between CMS and the HHS Office of Inspector General and discusses questions about how the delegated authority will operate.
Key points
- The firm’s article distinguishes mandatory and permissive exclusion authority.Sidley
- Sidley’s analysis compares exclusions with payment suspensions and billing-privilege revocations.Sidley
- The firm’s publication discusses exclusion hearings and rulemaking powers.Sidley
- Sidley’s article examines the payment consequences of excluding a provider.Sidley