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Howard Young

Howard Young

Morgan Lewis


Latest Publications

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OIG Revises Special Advisory Bulletin on Exclusions

OIG continues its aggressive interpretation of scope and effect of exclusion from participation in Federal health care programs and clarifies several open questions....more

5/10/2013 - Affordable Care Act Civil Monetary Penalty CMS Exclusions Health Plan Sponsors Healthcare OIG Payment Plans

HHS OIG Issues Report on Hospice General Inpatient Care Billing

Report makes no formal recommendations, but OIG notes that lengths of stay and frequency of general inpatient care are issues requiring further scrutiny....more

5/9/2013 - Billing HHS Hospice Medicare OIG

CMS Aims to Grease the Reporting Wheels for Medicare Fraud and Abuse

Proposed rule would substantially increase rewards for fraud tips and enhance billing revocation authority. On April 29, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule (Proposed Rule) that...more

4/30/2013 - CMS Fraud and Abuse Incentive Awards Medicare Proposed Regulation

HHS OIG Issues Revised Self-Disclosure Protocol

OIG touts substantial benefits of disclosing, provides greater detail for different types of disclosures, and captures 15 years of OIG Self-Disclosure Protocol experience....more

4/18/2013 - Anti-Kickback Statute Damages HHS OIG Self-Disclosure Requirements Stark Law

Protections to Be Extended for Electronic Health Record Donations

CMS and OIG issue similar proposed rules to modify the electronic health record exception and safe harbor. On April 10, the Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) of...more

4/17/2013 - CMS EHR Final Rules OIG Proposed Amendments Safe Harbors

OCR Reaches $50,000 Settlement with Hospice for Small Data Breach

Enforcement action sends a strong message to the healthcare industry and reaffirms the need for security risk analysis and mobile-device security policies and procedures....more

1/8/2013 - Data Breach Data Protection Electronic Medical Records HIPAA HITECH HONI Mobile Devices OCR PHI Settlement

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