On December 28, the U.S. District Court for the Northern District of California issued a nationwide preliminary injunction blocking implementation of the Most Favored Nation (MFN) Model. The decision prevents the Centers for Medicare & Medicaid Services (CMS) from implementing the MFN Model until the agency completes the notice and comment procedures required by the Administrative Procedure Act, which requires CMS to solicit comments on a proposal and respond to those comments before finalizing any rules implementing a new payment model. READ MORE