On March 2, 2020, the Securities and Exchange Commission (the “SEC”) released its final rule amending the financial disclosure requirements applicable to registered debt offerings that include credit enhancements, including...more
3/6/2020
/ Amended Regulation ,
Disclosure Requirements ,
Final Rules ,
Financial Statements ,
New Rules ,
Parent Corporation ,
Publicly-Traded Companies ,
Regulation S-X ,
REIT ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Subsidiaries ,
UPREITS
Healthcare systems, hospital networks, and other healthcare providers regularly face challenges that may require an internal investigation to determine the root cause of an issue in order to evaluate how best to remediate and...more
11/12/2019
/ Auditors ,
Audits ,
Best Practices ,
Data Preservation ,
False Claims Act (FCA) ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Internal Investigations ,
Medicare ,
Overpayment ,
Publicly-Traded Companies ,
Risk Management ,
Witnesses
On April 30, 2019, DOJ’s Criminal Division announced the release of an updated version of guidance previously issued in February 2017 regarding the evaluation of corporate compliance programs (Revised DOJ Compliance...more
Hospice providers continue to face increased scrutiny and enforcement actions based on allegations that beneficiaries do not meet the requisite eligibility requirements. On October 1, 2018, a United States District Court...more
On June 28, 2018, the U.S. District Court for the Northern District of Texas granted a motion for preliminary injunction which prevents CMS from recouping alleged overpayments of approximately $7.5 million from Family...more
On June 5, 2018, the Medicare Boards of Trustees (the Board) released its annual report on the fiscal condition of the Medicare trust funds: the Hospital Insurance (HI) trust fund, which supports Medicare Part A, and the...more
On April 24, 2018, the Centers for Medicare & Medicaid Services (CMS) released the Fiscal Year (FY) 2019 Inpatient Prospective Payment System (IPPS) Proposed Rule (CMS-1694-P). Among other changes, CMS proposes eliminating...more
On April 4, 2018, the United States Court of Appeals for the First Circuit affirmed a district court ruling that rejected CMS’s enforcement of two FAQs that clarified how certain reimbursements made to hospitals for...more
As previously reported, UnitedHealthcare Insurance Company (United) is challenging CMS’s Medicare C/D Overpayment Rule as it applies to Medicare Advantage (MA) organizations. HHS sought to stay United’s lawsuit while it...more
On March 27, 2017, in conjunction with the Health Care Compliance Association annual Compliance Institute, HHS OIG released a Resource Guide for the healthcare industry to facilitate the consideration of potential options for...more
On March 27, 2017, in conjunction with the Health Care Compliance Association (“HCCA”) annual Compliance Institute (“CI”), the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”) released...more
On January 4, 2017, the court in the American Hospital Association (AHA) v. Burwell litigation denied HHS’s motion to reconsider, which means that HHS must comply with the court’s timeline to eliminate the Medicare appeals...more
As previously reported, the American Hospital Association (AHA) filed suit against HHS in 2014 in connection with the Medicare appeals backlog and requested that the court force HHS to meet its statutory deadline for...more
On November 7, 2016, in the pending American Hospital Association (AHA) v. Burwell litigation, HHS filed a motion for summary judgment. A central focus of HHS’s motion for summary judgment is assertions that “the backlog is...more
In August 2016, OIG released a series of reports focusing on the Medicaid electronic health record (EHR) incentive program for hospitals in West Virginia, Ohio, and Oklahoma. This continues a recent trend of reports focusing...more
On August 23, 2016, a New York hospital system settled False Claims Act (FCA) allegations that it violated the 60-day overpayment rule by improperly retaining Medicaid overpayments. The whistleblower alleged that three of the...more
8/30/2016
/ 60-Day Rule ,
Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
Comptroller ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Hospitals ,
Medicaid ,
Medicare ,
Overpayment ,
Overpayment Recovery Time Limits ,
Whistleblowers