Rose Willis

Rose Willis

Dickinson Wright

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Expansion of Practice Autonomy of Physician Assistants Summary

As part of a flurry of activity at the end of 2016, Public Act 379 was enacted by the Michigan legislature and signed by Governor Snyder. That Act amends various provisions of the Michigan Public Health Code (the “Code”)...more

1/24/2017 - Amended Legislation Physician Assistants Physicians Public Health

Affordable Care Act Repeal

Recently the Wall Street Journal stated the New England Journal of Medicine published an op-ed by President Obama in which he critiqued the Republicans’ strategy to repeal the Affordable Care Act, and then replace it at a...more

1/13/2017 - Affordable Care Act Barack Obama Fraud and Abuse Repeal Wall Street Journal

What Physician Practices and Other Healthcare Providers Need to Know About the Posting and Grievance Obligations Set Forth in the...

Section 1557 of the Affordable Care Act prohibits discrimination on the basis of race, color, national origin, sex, age, or disability. Recently, the Federal Office for Civil Rights (“OCR”) issued a Final Rule clarifying...more

10/18/2016 - Affordable Care Act Final Rules Grievance Process Health Care Providers Meaningful Use Medicare Part B Non-Discrimination Rules OCR Physicians Posting Requirements Section 1557

New HIPAA Guidance on Ransomware Prevention and Recovery

A U.S. government interagency report indicates that there has been a 300 percent increase in the daily ransomware attacks in 2016 as compared to 2015. Ransomware is malicious software that, when introduced into a system,...more

7/19/2016 - Business Associates Covered Entities HIPAA Information Reports New Guidance PHI Ransomware

Navigating Michigan’s Corporate Practice of Medicine Doctrine in the Accountable Care Organization Environment

Accountable Care Organizations (ACOs) are organizations that have accepted responsibility for the overall quality, cost and care of a defined group of beneficiaries in compliance with the rules established by the federal...more

5/19/2016 - ACOs Business Formation Choice of Entity Corporate Practice of Medicine Professional Services Companies State and Local Government

Physician Compliance Programs: What you need to know about the Final 60-Day Rule

The 60-Day Rule was enacted as part of the Affordable Care Act on March 23, 2010 and generally requires a person who has received an overpayment to report and return the overpayment by the later of (i) the date which is 60...more

3/3/2016 - 60-Day Rule Affordable Care Act CMS False Claims Act (FCA) Final Rules Health Care Providers Medicare Overpayment

HIPAA Privacy Rule Amendment will Permit Very Limited Reporting of Mental Health Information to the NICS

An amendment to HIPAA’s privacy rules will allow a limited subset of covered entities (such as, potentially, state agencies) to disclose information to the National Instant Criminal Background Check System (NICS)....more

1/11/2016 - Covered Entities Criminal Background Checks Gun Laws HIPAA Mental Health NICS Popular Reporting Requirements

New Stark Law Exception Allows Hospitals, FQHCs and RHCs to Assist Physicians with Engaging Non-Physician Practitioners

The Centers for Medicare & Medicaid Services (CMS) recently released a new exception to the Physician Self-Referral Law (the “Stark Law”) intended to expand access to primary care and mental health services (the “NPP...more

11/23/2015 - CMS Exceptions FQHC Hospitals Rural Health Care Providers Stark Law

New CMS Proposed Rule Provides Who/What/When for Clinical Laboratory Reporting Requirements Starting January 1, 2016

Clinical laboratories will see significant changes to their Medicare payments for clinical diagnostic laboratory tests (CDLTs) starting January 1, 2017, but the basis for new payment rates will come from “applicable data”...more

10/9/2015 - ADLT CLFS CLIA Clinical Laboratories CMS Compliance HCPCS Managed Care Contracts Medicaid Medicare Part C PAMA Penalties Physician Fee Schedule Reporting Requirements

Healthcare Legal News: Volume 5, Number 1

CMS ANNOUNCES NEW RULES THAT MAKE OWNER DOCTORS LIABLE FOR ALL PRACTICE MEDICARE DEBTS - Even after they leave the Practice. CMS announced its final rules on "Medicare Provider Oversight" on December 3, 2014....more

2/19/2015 - ACOs CMS Fee-for-Service Final Rules Health Care Providers Health Insurance Healthcare Hospitals Medicare Shared Savings Program PHI Physicians Quality of Care Standards

HHS Aggressive Goals for Value Based Payments

In a brief article published last week in the New England Journal of Medicine, Sylvia Burwell, the U.S. Secretary of Health and Human Services (HHS), summarily set forth HHS's efforts for improving the U.S. health care...more

2/3/2015 - Fee-for-Service Healthcare HHS Quality of Care Standards

Arrangements between Laboratories and Referring Physicians Involving “Registries”

The United States Office of Inspector General (“OIG”) recently issued a “Special Fraud Alert” focusing on two potentially illegal trends that it has detected in arrangements between laboratories and their referring...more

11/10/2014 - Clinical Laboratories Healthcare Healthcare Fraud OIG Physicians

Complying with Recent Changes to the Physician’s Notice of Privacy Practices

A physician practice’s Notice of Privacy Practices (“NPP”) acts as the “roadmap” to the practice’s permitted uses and disclosures of their patients’ protected health information (“PHI”). ...more

10/17/2014 - Final Rules HIPAA Notice of Privacy Practices PHI Physicians

Healthcare Legal News: Volume 4, Number 3 - Special Issue: HIPAA Update

Recent Trends in HIPAA Liability - Since the passage of the 2013 HIPAA Omnibus Rule, there has been a substantial increase in HIPAA enforcement actions brought by the Department of Health and Human Services, including...more

9/17/2014 - Data Protection EHR Healthcare Healthcare Reform HIPAA HIPAA Omnibus Rule PHI

Laboratory Payments to Physicians for Specimen Processing Present Substantial Risk of Fraud and Abuse

The United States Office of Inspector General (“OIG”) recently issued a “Special Fraud Alert” focusing on two potentially illegal trends that it has detected in arrangements between laboratories and their referring...more

8/15/2014 - Fraud Fraud and Abuse Healthcare Healthcare Fraud Laboratories OIG Physicians

HIPAA Violation Results in $4.8 Million Settlement

While most healthcare providers know to pay close attention to the HIPAA rules when setting up their information technology systems, recent events have demonstrated that this close scrutiny should also be applied to computer...more

7/10/2014 - Cybersecurity Data Breach Healthcare HHS HIPAA Hospitals OCR PHI Search Engines Settlement

Healthcare Legal News - July 2014 • Volume 4, Number 2

In This Issue: - DO SUBSIDIZED HEALTH CARE PLANS PURCHASED UNDER THE AFFORDABLE CARE ACT TRIGGER THE ANTI-KICKBACK STATUTE? The advent of federally subsidized private pay health insurance under the Affordable...more

7/7/2014 - Affordable Care Act Anti-Kickback Statute CMS Healthcare Healthcare Reform Medicaid Medicare Popular TRICARE

Windows XP Use May Violate HIPAA Starting April 8, 2014

If you use Windows XP on April 8, you will be easily susceptible to cyber-attacks and violations of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)....more

3/31/2014 - Cyber Attacks Cybersecurity Data Protection HIPAA

The 2014 OIG Work Plan: Select Provisions Applicable to Physician Practices

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently issued its 2014 Work Plan outlining its intended review activities of HHS Programs for 2014. This article summarizes certain...more

3/21/2014 - Healthcare HHS OIG Physicians

Healthcare Legal News - February 2014 • Volume 4, Number 1

In This Issue: - CMS ISSUES FINAL RULE ON DIRECT ACCESS OF LAB TEST RESULTS BY PATIENTS: On February 3, 2014, the Centers for Medicare and Medicaid Services (CMS) released a final rule that permits patients or...more

2/27/2014 - CMS EHR Health Insurance Healthcare Healthcare Reform HIPAA Hospitals Out of Network Provider PHI

Providers: Prepare Your Breach Notification Policy!

On December 26, 2013, Adult & Pediatric Dermatology, a dermatology practice located in Massachusetts, agreed to pay a $150,000 fine after it lost an unencrypted thumb drive containing over 2,000 patients’ health records, and...more

1/3/2014 - Breach Notification Rule Data Breach Data Protection HHS HITECH PHI

Health Care Legal News - August 7, 2013 • Volume 3, Number 2


8/7/2013 - Affordable Care Act Delays Employer Mandates Healthcare IRS Pay or Play Reporting Requirements Shared Responsibility Rule Transition Relief

Health Care Legal News - January 31, 2013 • Volume 3, Number 1


2/5/2013 - Data Breach Disclosure Requirements HIPAA HIPAA Omnibus Rule HITECH Immunization Records Marketing Notice of Privacy Practices Notice Requirements PHI Students

The HIPAA “Omnibus” Final Rule - Revisions to the Rules on Breach Notification; Notice of Privacy Practices; and Marketing and...

The United States Department of Health and Human Services (the "Department") issued the "Omnibus" Final Rule (the "Final Rule") on January 17th, 2013. The Final Rule contains long-awaited rules and clarifications regarding...more

2/1/2013 - Data Breach Fundraisers HHS HIPAA HIPAA Omnibus Rule HITECH Marketing Notice Requirements OCR PHI Privacy Policy

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