News & Analysis as of

Health Care Providers Financial Assistance Policies

Mintz - Health Care Viewpoints

The OIG Issues New FAQs on Financial Assistance Policies and Marketing to Patients

On July 8, 2024, the Office of Inspector General (OIG) updated its General Questions on Fraud and Abuse Authorities (FAQs) related to the Anti-Kickback Statute (AKS) and the Beneficiary Inducement Prohibition of Civil...more

Roetzel & Andress

Updates to Statute 1557 that Healthcare Providers Need to Know

Roetzel & Andress on

Joining host Ericka Adler on the first #HealthlawHotSpot of 2024 is fellow Roetzel healthcare attorney Christina Kuta. Ericka and Christina will break down statute 1557 that prohibits discrimination from healthcare providers...more

Sheppard Mullin Richter & Hampton LLP

CFPB, other Federal Agencies Seek Public Comment about Medical Debt

On July 7, the CFPB, HHS, and Treasury announced a joint inquiry into high-cost specialty financial products which are being offered to patients as alternate forms of payment for routine medical care. Traditionally, these...more

Troutman Pepper

Federal Agencies Launch Inquiry Into Medical Payment Products

Troutman Pepper on

On July 7th, the Consumer Financial Protection Bureau (CFPB), U.S. Department of Health and Human Services, and the U.S. Department of Treasury (collectively, the agencies) jointly issued a Request for Information (Request)...more

Ballard Spahr LLP

CFPB, jointly with Dept. of Health and Human Services and Dept. of Treasury, issues request for information regarding medical...

Ballard Spahr LLP on

In advance of a hearing scheduled for today on medical billing and collections in which the focus will be medical payment products such as medical credit cards and installment loans, the CFPB, jointly with the U.S. Department...more

Sheppard Mullin Richter & Hampton LLP

HHS Issues Proposed Rule to Provide Clarity on Rights of Conscience in Healthcare

On January 5, 2023, the U.S. Department of Health and Human Services (“HHS”) published a notice of proposed rulemaking entitled “Safeguarding the Rights of Conscience as Protected by Federal Statutes” (the “Proposed Rule“)....more

White & Case LLP

COVID-19: Summary of Legal Measures in Russia

White & Case LLP on

This summary is intended to help navigate a large number of legal measures taken by the Russian authorities in connection with COVID-19. The review is not exhaustive. We plan to periodically update this document as new...more

Dechert LLP

European Anti-Fraud Office (“OLAF”) remains active during COVID-19 crisis and targets increase in investigation and prosecution of...

Dechert LLP on

The Director-General of OLAF, Ville Itälä, has indicated in a recent interview that OLAF is seeking to coordinate more with authorities in EU Member States to increase the number of prosecutions brought for EU budget fraud....more

Foley Hoag LLP

The $2 Trillion Federal CARES Act: The Key Financial Assistance Provisions, Key Legislative Changes, and Next Steps

Foley Hoag LLP on

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is a comprehensive economic relief plan designed to stabilize and uplift the American economy during the COVID-19 pandemic. It is unique not only because...more

Robinson+Cole Health Law Diagnosis

DOJ Reaches Settlement with Patient Assistance Foundation Resolving Allegations of FCA Violations

On January 21, 2020, the Department of Justice (DOJ) announced a $3 million settlement with Patient Services, Inc. (PSI) to resolve allegations of False Claims Act (FCA) violations. The DOJ alleged that PSI enabled three...more

Ballard Spahr LLP

HHS Proposes to Scale Back ACA Nondiscrimination Rules

Ballard Spahr LLP on

The U.S. Department of Health and Human Services (HHS) has released proposed regulations that, if finalized, will significantly narrow the scope of the nondiscrimination requirements under Section 1557 of the Affordable Care...more

Bracewell LLP

Hospital Loses its Section 501(c)(3) Status Due to Noncompliance with Section 501(r)

Bracewell LLP on

The IRS recently issued a Private Letter Ruling (the “PLR”) revoking a hospital organization’s section 501(c)(3) status for failing to comply with the section 501(r) requirements. In what may be a sign of things to come, the...more

Burr & Forman

Can I Waive a Patient’s Co-Pay?

Burr & Forman on

I am occasionally asked by providers whether or not they can waive a co-pay for a particular patient. There are many reasons providers wish to waive co-pays: financial hardship, professional courtesy, employee discounts, etc....more

Bradley Arant Boult Cummings LLP

The Giving Season Is Over: Practical Advice for Patient Assistance Programs in the Wake of United Therapeutics’ $210 Million False...

Right before Christmas last year, the Department of Justice (DOJ) announced an ominous settlement: United Therapeutics, a manufacturer of pulmonary arterial hypertension drugs, agreed to pay more than $200 million to settle...more

Pullman & Comley - Connecticut Health Law

Hospitals, Physician Practices and Clinics are Reminded to Post New Non-Discrimination Notice

Hospitals, physician practices and other health care providers that receive federal financial assistance, which includes receiving reimbursement from Medicare Parts A, C and D and/or Medicaid, are reminded to post new...more

Franczek P.C.

HHS Issues Final Rule on ACA Nondiscrimination in Health Programs and Activities

Franczek P.C. on

On May 18, 2016, the Department of Health and Human Services (“HHS”) issued final regulations interpreting the nondiscrimination provisions of Section 1557 of the Affordable Care Act (“ACA”). The rule mainly impacts insurers...more

Carlton Fields

New Patient Transparency Requirements for Hospitals and ASCs

Carlton Fields on

Governor Scott signed into law House Bill 1175 relating to Transparency in Health Care. The new law makes several changes to existing laws regulating the licensure of hospitals and ambulatory surgical centers (ASCs). ...more

Akerman LLP - Health Law Rx

CMS Publishes Notice of Proposed Rule Making Regarding Stark Law Amendments and Seeks Comment on the Issue of Stark Acting as a...

In early July, the Centers for Medicare and Medicaid Services (CMS) published a notice of proposed rulemaking, amending the Physician Self-Referral Prohibitions, or Stark law. 80 Fed. Reg. 41,909-930 (July 15, 2015). The...more

Locke Lord LLP

IRS Clarifies Financial Assistance Policy Requirements for Charitable Hospital Organizations

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The Internal Revenue Service (IRS) has clarified the requirements for charitable hospital organizations required to adopt a financial assistance policy. For large hospitals or hospitals using the services of multiple private...more

Akerman LLP - Health Law Rx

IRS Says Hospitals Must List Physicians in Financial Assistance Policies

On June 26, 2015, the Internal Revenue Service (IRS) issued guidance to clarify how charitable hospitals may comply with regulations issued by the Department of Treasury under the Patient Protection and Affordable Care Act...more

Polsinelli

IRS Clarifies Requirements for Listing Providers in Financial Assistance Policies

Polsinelli on

On June 26, 2015, the Internal Revenue Service (IRS) released Notice 2015-46, which clarifies the requirement in the Treasury Regulations under Section 501(r)(4) that a hospital's financial assistance policy (FAP) must...more

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