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Exclusions Enforcement

BCLP

CFPB guidance on pay-to-pay fees impacts consumer loan agreements

BCLP on

Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more

Holland & Knight LLP

Education Department Ceases Enforcement of "Arbitrary and Capricious" Exclusionary Rule

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By a bulletin and letter issued on Aug. 24, 2021, the Biden Administration's U.S. Department of Education announced that it was ceasing enforcement of a highly controversial exclusion of evidence rule that was included in the...more

BakerHostetler

OIG Revamps Regulations Concerning CMPs and Exclusion

BakerHostetler on

In a pair of proposed rules published in May, the HHS OIG unveiled changes to the regulations concerning OIG’s authority to impose civil monetary penalties (CMPs) and exclude individuals and entities from participation in...more

Holland & Knight LLP

CMS Issues Final Physician Payment Sunshine Rule

Holland & Knight LLP on

In an action that will have broad implications for drug and device manufacturers, researchers, distributors, teaching hospitals and physicians, on February 1, the Centers for Medicare and Medicaid Services (CMS) publicly...more

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