Laws & Regulations

About Laws & Regulations

Navigating the vast network of health care laws and regulations is difficult. To help hospitals, CHA produces manuals and guidebooks, including the Consent Manual, a one-stop resource for all legal requirements related to patient consent for medical treatment, release of medical information, reporting requirements and more; the Model Medical Staff Bylaws and Rules, which outline the framework for working relationships among medical staff, hospital administrators and governing bodies; and the California Hospital Compliance Manual, which covers high-risk compliance issues. CHA also represents California hospitals’ interests in court on issues, including reimbursement, labor and employment, and more.

CMS Proposes Inadequate Outpatient Payment Update

What’s happening: The Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2025 outpatient prospective payment system proposed rule.  

What else to know: The rule includes a net market basket update of 2.6%. As a result of all proposed changes, CMS estimates that hospital outpatient payments will increase by $1.8 billion in CY 2025, excluding changes in enrollment, case mix, and utilization.  

Letters to OHCA Board Highlight New Data, Caution Against Overly Broad Review Process

What’s happening: Last week, CHA submitted two letters to the Office of Health Care Affordability (OHCA) — one responding to the May OHCA board meeting, and another addressing the office’s proposed changes to the cost and market impact review (CMIR) regulations.  

What else to know: The board met June 26 to approve the alternative payment model (APM) standards and discuss the proposed CMIR regulations, the draft workforce stability standards, and the draft primary care investment benchmark.   

ONC Finalizes Financial Penalties for Information Blocking

What’s happening: The Office of the National Coordinator for Health Information Technology (ONC) issued a final rule on provider disincentives for information blocking.    

What else to know: CHA is disappointed in the finalized policies and remains concerned about the selective application of penalties to certain health care providers, as previously outlined in comments

CMS Proposes Inadequate Home Health Payment Update

What’s happening: The Centers for Medicare & Medicaid Services issued a proposed calendar year (CY) 2025 home health prospective payment system.  

What else to know: CMS estimates payments to home health agencies, as a result of the changes in the proposed rule, will decrease by $280 million (1.7%). Other key provisions of the proposed rule include: 

Extension Announced for IDR Disputes Impacted by Change Healthcare Cyberattack

What’s happening: The departments of Health & Human Services, Labor, and Treasury (departments) announced a 120-day extension for parties impacted by the Change Healthcare cyberattack to open disputes under the No Surprises Act independent dispute resolution (IDR) process.  

What else to know: Disputes must be filed by Oct. 12, and parties must attest that their ability to open a dispute was affected by the incident in February.