Elizabeth Gebarski

January 1, 2024 ushered in a new year and new changes to the Illinois Antitrust Act, the State Finance Act, and the Illinois Health Facilities Planning Act. These changes result in new requirements for certain “health care facilities” or “provider organizations” undergoing a change of ownership and inject Illinois Attorney General (“Illinois AG”) oversight and discretionary involvement in a variety of transactions.

It pays to look closely. Buried deep within a 205-page and 1230-page Federal Register final rules publication, the Centers for Medicare & Medicaid Services (“CMS”) initiated impactful changes for pharmacies and Durable Medical Equipment, Prosthetics, Orthotics and Supplies (“DMEPOS”) suppliers.

We spent a couple lovely days with the Western Medicaid Pharmacy Administrators Association members in Tucson, Arizona. The following is a summary of key focus areas for many of the member states: Pharmacists enrolling as providers – Many states are grappling with enrolling pharmacists as Medicaid providers. Some states are experiencing low enrollment volume, which is making it hard to justify permitting the enrollment.