On April 5, 2013, David Blass, Chief Counsel of the SEC’s Division of Trading and Markets (which regulates broker-dealers), gave an important speech highlighting two “significant areas of concern” about broker-dealer...more
The electronic prescribing and electronic health records (“EHR”) exceptions to the federal physician self-referral law known as the Stark Law (42 U.S.C. § 1395nn) were first published in the Federal Register in 2006, yet they...more
On January 7, 2012, the OIG posted Advisory Opinion No. 12-22 to address a co-management arrangement between a hospital and physicians that is designed to align incentives by offering compensation based on quality, service,...more
On January 1, 2013, AB 2103 went into effect, explicitly overturning the case of Arechiga v. Delores Press, Inc., 192 Cal. App. 4th 567 (2011), and prohibiting compensation agreements that guarantee nonexempt employees a...more
Do you have any employees that are paid on a commission basis? If so, do you have a written contract setting forth the terms and conditions by which commissions will be earned and paid? Has the contract been signed by the...more
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