Gregory Fliszar

Gregory Fliszar

Cozen O'Connor

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OIG’s New Work Plan Focuses on the Security of Health Information

On October 31, 2014, The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released its Work Plan for fiscal year (FY) 2015. The Work Plan summarizes “new and ongoing reviews of activities...more

12/5/2014 - HHS HIPAA OIG Patient Privacy Rights PHI Work Plans

CMS Withdraws Proposed Medicare Secondary Payer Rule

On October 8, 2014, the Centers for Medicare & Medicaid Services (“CMS”) withdrew its Notice of Proposed Rule Making (“NPRM”) from the Office of Management and Budget that was to address how Medicare’s future interests should...more

10/20/2014 - Auto Insurance CMS Liability Insurance Medicare Medicare Secondary Payer Act No-Fault Insurance NPRM

HHS Releases a New Security Risk Assessment Tool

The Department of Health and Human Services (HHS) recently released a new security risk assessment (SRA) tool for small- to medium-sized health care providers. HIPAA requires covered entities to conduct periodic assessments...more

4/30/2014 - HHS HIPAA Risk Assessment

HIPAA Audits Set to Begin in 2014: Another Enforcement Mechanism for HIPAA Compliance

The Department of Health and Human Services (HHS) is expected to launch its long-awaited HIPAA audit program sometime in 2014. The audit program will be run by HHS’ Office of Civil Rights (OCR), which is likely eager to get...more

3/7/2014 - Audits Compliance HHS HIPAA HITECH

Hospitals Prevail in Effort to Include Pennsylvania GA Days in the Medicare DSH Calculation

Two of Mercy Health System’s hospitals (Nazareth Hospital and the former St. Agnes Medical Center) successfully challenged, before Judge Ludwig of the U.S. District Court for the Eastern District of Pennsylvania, the...more

5/1/2013 - CMS DSH Eligibility Healthcare Hospitals Medicare Waivers

Highlights of the Omnibus HIPAA/HITECH Final Rule

On January 25, 2013, the Office of Civil Rights (OCR) of the Department of Health & Human Services (HHS) published the long-awaited omnibus final regulation governing health data privacy, security and enforcement (Omnibus...more

3/7/2013 - Affirmative Defenses Business Associates Compliance Data Breach Enforcement Fundraisers GINA HHS HIPAA HIPAA Omnibus Rule HITECH Marketing Notice Requirements Penalties PHI Subcontractors

HHS Releases the Long-Awaited Final Omnibus HIPAA Rules

A pre-publication version of the much anticipated final Omnibus Health Insurance Portability and Accountability Act (HIPAA) rule (the Final Rule) was issued January 17, 2013 with publication in the Federal Register scheduled...more

1/22/2013 - Business Associates Data Protection GINA HHS HIPAA HIPAA Omnibus Rule PHI

The SMART Act: A Bipartisan Attempt to Make the MSP Act Workable

On January 10, 2013, President Obama signed into law H.R. 1845, which includes the Strengthening Medicare and Repaying Taxpayers Act of 2011 (SMART Act). The SMART Act amends several portions of the Medicare Secondary Payer...more

1/17/2013 - Health Insurance Medicare Medicare Secondary Payer Act SMART

HIPAA Enforcement – The Gathering Storm Has Arrived

Since the Health Insurance Portability and Accountability Act (HIPAA) privacy rules became effective in April 2003, there has been minimal enforcement activity by the U.S. Department of Health and Human Services (HHS) Office...more

11/16/2012 - Data Breach Data Protection HIPAA HITECH OCR Patient Privacy Rights PHI

Seventh Circuit Rules that Medical Necessity Trumps State-Imposed Cap on “Optional” Medicaid Coverage

In a class action lawsuit, the U.S. Court of Appeals for the 7th Circuit recently affirmed a lower court decision granting a preliminary injunction that prevented the state of Indiana from enforcing a $1,000 annual cap on...more

10/24/2012 - Affordable Care Act Class Action Medicaid Medical Benefits Preliminary Injunctions

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