Renee M. Howard

Renee M. Howard

Perkins Coie

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New Rules Amend Regulatory Exceptions For Donation Of Electronic Health Records Items And Services

On December 27, 2013, the Department of Health and Human Services published two final rules, one amending the Office of Inspector General’s (OIG) Anti-Kickback safe harbor related to electronic health records (EHR) items and...more

1/6/2014 - CMS Cybersecurity Data Protection EHR Healthcare Medicaid Medicare PHI Stark Law

Oregon Settlement Expands Disclosure Obligations Of Physicians Receiving Payments From Drug And Device Manufacturers

As of August 1, 2013, pharmaceutical companies and medical device manufacturers are required to report to the federal government payments made to physicians under the Physician Payment Sunshine Act (PPSA). ...more

8/23/2013

CMS Adopts New “2 Midnights” Presumption For Inpatient Hospital Admissions

On August 2, 2013, the Centers for Medicare and Medicaid Services (CMS) issued an advance copy of its final rulemaking that adopts a new approach to evaluating the medical necessity of inpatient hospital admissions. ...more

8/9/2013 - CMS Fraud Healthcare Hospitals Medicare Medicare Part A Required Documentation

Hospitals Provided Temporary Relief In Medicare Rebilling Policy

The Centers for Medicare & Medicaid Services (CMS) released a ruling and an interim rule that, effective immediately, will allow hospitals to rebill certain inpatient hospital services as outpatient services for one year...more

3/21/2013 - American Hospital Association Audits Billing CMS Hospitals Medicare

U.S. Supreme Court Holds Equitable Tolling Doctrine Does Not Apply To Administrative Appeal Deadline

On January 22, 2013, the U.S. Supreme Court issued a unanimous decision in Sebelius v. Auburn Regional Medical Center, 568 U.S. _____ (2013), holding that hospitals cannot appeal Medicare inpatient reimbursement...more

1/28/2013 - Administrative Appeals Equitable Tolling Kathleen Sebelius Medicare Physician Medicare Reimbursements SCOTUS Sebelius v Auburn Regional Medical Center

In Landmark Decision, Second Circuit Reverses Conviction For Off-Label Promotion

On December 3, 2012, in United States v. Caronia, a three-judge panel of the Second Circuit reversed a drug salesperson’s conviction for conspiracy to introduce a misbranded drug into interstate commerce, a misdemeanor...more

12/7/2012 - FDCA First Amendment Off-Label Promotion Off-Label Use Pharmaceutical

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