While much of the national press has focused on the various lawsuits around the country challenging the constitutionality of the Patient Protection and Affordable Care Act (“ACA”), the Centers for Medicare and Medicaid Services (“CMS”) continues to forge ahead with the ACA’s many statutorily mandated programs and requirements. Although parties may disagree over the outcomes and political effects of the various lawsuits, there is no doubt that CMS continues to implement rules and programs under the ACA that have far-reaching consequences for the delivery of health care throughout the country.
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