Richard Rifenbark

Richard Rifenbark

Foley & Lardner LLP

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Latest Publications


OIG Releases Compliance Guidance for Health Care Governing Boards

The Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“DHHS”) released new compliance guidance for health care governing boards, attorneys, compliance officers and internal auditors on...more

5/4/2015 - Board of Directors Chief Compliance Officers Corporate Governance Health Care Providers Internal Audit Functions New Guidance OIG

CMS Releases Stage 3 Meaningful Use Proposed Rule

The Centers for Medicare & Medicaid Services (“CMS”) released the Stage 3 proposed rule to the Medicare and Medicaid Electronic Health Records Incentive Programs (“Proposed Rule”) on March 20, 2015. To provide context,...more

4/3/2015 - CMS EHR Health Care Providers Hospitals Meaningful Use Medicaid Medicare Physicians Proposed Regulation

How to Prepare Your Hospital or Medical Practice for a Meaningful Use Audit

For the past several years, the Centers for Medicare and Medicaid Services (“CMS”) has incentivized hospitals and eligible professionals to adopt and make “meaningful use” of certified electronic health records (“EHR”)...more

12/19/2014 - Audits CMS Electronic Health Record Incentives Healthcare Facilities Hospitals Meaningful Use Physicians

GAO Issues Report on Post-Payment Claims Reviews by CMS Contractors

The U.S. Government Accountability Office (GAO) recently issued a report entitled “Medicare Program Integrity: Increased Oversight and Guidance Could Improve Effectiveness and Efficiency of Post-Payment Claims Reviews,” which...more

8/29/2014 - CMS GAO MACs Medicare Recovery Audit Contractors (RACs) ZPIC

CMS and OIG Issue Final Regulations to Extend the Stark Exception and Anti-Kickback Statute Safe Harbor for EHR Donations

On December 27, 2013, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services’ Office of Inspector General (OIG) finalized amendments to the Physician Self-Referral Law (Stark) and...more

1/17/2014 - Anti-Kickback Statute CMS EHR Healthcare HHS OIG Safe Harbors Stark Law Sunset Provisions

CMS and OIG Issue Proposed Rules Modifying the Stark Exception and Anti-Kickback Safe Harbor for Donation of EHR

On April 10, 2013, the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) each published proposed rules in the Federal Register...more

4/19/2013 - Anti-Kickback Statute CMS EHR OIG Proposed Regulation Stark Law Sunset Provisions

First-Ever HIPAA Settlement Involving Fewer Than 500 Patients Announced

On January 2, 2013, the U.S. Department of Health and Human Services (HHS) announced a settlement with the Hospice of North Idaho (HONI) for potential HIPAA violations....more

1/8/2013 - Compliance Data Breach Data Protection Health Information Technologies HHS HIPAA HONI Mobile Devices OCR Patient Confidentiality Breaches Settlement

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