On November 21, an internal HHS memorandum addressed to Centers for Medicare & Medicaid Services (CMS) Principal Deputy Administrator Demetrios Kouzoukas entitled “Impact of Allina on Medicare Payment Rules” became publicly available.  The memorandum addresses the HHS Office of the General Counsel’s (OGC) “views on the impact of Azar v. Allina Health Services, 139 S. … Continue reading