Sarah S. Fallows

Sarah S. Fallows

Davis Wright Tremaine LLP

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OIG Fraud Alert: Physicians in the Cross Hairs

On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) issued a Fraud Alert focused on physician relationships. The Alert cautions physicians who enter into compensation arrangements...more

6/18/2015 - Anti-Kickback Statute Fair Market Value Fraud Alerts Healthcare HHS Hospitals Medical Directors OIG Physician Compensation Arrangements Physicians

Medicare Shared Savings Program: Final Rule

Last week, the Centers for Medicare & Medicaid Services (CMS) released its Final Rule on the Medicare Shared Savings Program (MSSP). The Final Rule provides additional flexibility to accountable care organizations...more

6/17/2015 - ACOs CMS Data-Sharing Electronic Health Record Incentives Fee-for-Service Final Rules Medicaid Medicare Medicare Shared Savings Program Telehealth

Touching Up that Old Two Step: CMS Proposes Revisions to its Beneficiary Assignment Methodology

On Dec. 1, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses...more

12/24/2014 - ACOs CMS Healthcare Medicare Shared Savings Program Proposed Regulation

Changing Basic Rules of the Game: CMS Proposed Rule Relating to ACO Governance and Contracting

The Centers for Medicare and Medicaid Services released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory expands upon our initial...more

12/19/2014 - ACOs CMS Healthcare Medicare Shared Savings Program Proposed Regulation

Keeping Track of the Tracks: Proposed ACO Regulations Alter MSSP Financial Models

Last week, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses on...more

12/12/2014 - ACOs CMS Medicare Medicare Shared Savings Program

CMS Releases Proposed New Rule for Accountable Care Organizations

On Dec. 1st, the Centers for Medicare and Medicaid Services released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). The voluminous proposal covers a...more

12/5/2014 - ACOs CMS Comment Period Healthcare Medicare Shared Savings Program Proposed Regulation

Surviving the AG Conversion Process: Tips for Nonprofit Hospitals

Any manager of a nonprofit health facility involved in a sale, merger or other affiliation knows that undergoing such complicated transactions can become a major distraction from the day-to-day task of running the facility. A...more

7/24/2014 - Due Diligence Healthcare Hospitals Mergers Non-Profits

FTC’s 50th Data Security Settlement Sends a Message: Be Careful with Overseas Contractors

The Federal Trade Commission (FTC) sent a message about the importance of imposing appropriate security measures on—and monitoring—vendors with access to confidential consumer information. The FTC issued a 20-year consent...more

2/5/2014 - Compliance Contractors Data Breach Data Protection Due Diligence FTC Vendors

It’s Not Enough to Notify: Don’t Forget the Policies, Risk Analyses, and Training

HIPAA compliance ended with a bang in 2013, with the feds issuing the first settlement involving a health provider’s failure to have breach notification policies and procedures in place. On Dec. 24, 2013, the Department of...more

1/8/2014 - Compliance HHS HIPAA OCR Security Rule Training

OIG Special Fraud Alert Labels Physician-Owned Distributorships (PODs) as “Inherently Suspect”

The U.S. Department of Health & Human Services, Office of Inspector General (the “OIG”) issued a Special Fraud Alert (“Alert”) on March 26, underscoring its heightened focus on fraud and abuse risks posed by physician-owned...more

4/22/2013 - Anti-Kickback Statute Fraud Healthcare HHS Medical Devices OIG Physician-Owned Distributors Physicians

Clock Running on Comment Period for Meaningful Use Stage 3 Measures

On Nov. 16, 2012, the Office of the National Coordinator for Health Information Technology (ONC) released a request for comment regarding Stage 3 meaningful use measures, taking a step forward in the ongoing effort to define...more

12/12/2012 - Health Information Technologies Meaningful Use Medicaid Medicare

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