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Articles by Steve Komorek
U.S. Drug Pricing Year in Review: Reflections on 2025 and Getting Ready for 2026
In 2025, legal pressures on federal drug pricing policy escalated to a fever pitch. The Trump administration resurrected a version of its most-favored-nation (MFN) drug pricing policy from President Donald Trump’s first term and continued implementation of Maximum Fair Price (MFP) requirements under the Inflation Reduction Act (IRA).
Medicare Part D’s New Cost-Smoothing Program: Key Insights and Impacts
Beginning in January 2025, Medicare Part D prescription drug plans, including stand-alone and Medicare Advantage Part D Plans, must provide enrollees with the option to smooth their out-of-pocket (OOP) prescription drug costs (capped at $2,000 in CY2025) evenly throughout the plan year.
Steve Komorek | People | Sidley Austin LLP
STEVE KOMOREK focuses his practice on healthcare regulatory and compliance matters. He provides strategic, day-to-day counsel on fraud and abuse issues under the federal Anti-Kickback Statute, Eliminating Kickbacks in Recovery Act, and False Claims Act. Steve also advises clients on the Inflation Reduction Act, the Sunshine Act, Medicare and Medicaid coverage and reimbursement, as well as the development and implementation of healthcare compliance programs.
Inflation Reduction Act: CMS Solicits Comments on Price Negotiation Program Guidance, Makes Part B Coinsurance Announcements
On March 15, the Centers for Medicare and Medicaid Services (CMS) made a series of important announcements regarding implementation of the Inflation Reduction Act (IRA). Most crucially, CMS issued new initial guidance on implementation of the Medicare Drug Price Negotiation Program (Medicare Drug Price Program), with public comments due April 14, 2023. Notably, CMS did not issue the initial guidance through notice and comment rulemaking.
Proposed Behavioral Health Updates in Medicare Advantage and ACA Marketplace Plans Could Lead to Enhanced Access and Opportunities
Investors and practice management companies focused on behavioral health should note two recent proposed rules that, if finalized, should increase access to behavioral health services for beneficiaries enrolled in Medicare Advantage (MA) health plans and Patient Protection and Affordable Care Act (ACA) marketplace plans.
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