Victor On-Sang is a litigation associate at Wolfe Pincavage. As part of the litigation practice group, Victor provides strategic, operational, and litigation support to the firm’s healthcare clientele. He tackles a wide array of complex healthcare disputes, including those involving ERISA, the ACA, state insurance laws, Medicare Advantage, and federal and state regulatory matters.
This proposal reflects a broader shift toward more restrictive oversight of inpatient utilization. As CMS finalizes this policy, providers should be aware of the immediate compliance and reimbursement risks associated with the phase-out.