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New York State OMIG Makes Regulatory Modifications to Compliance Program Requirements

It is axiomatic that New York State requires every Medicaid provider to have an “effective” compliance program.  New York Social Services Law § 363-d.  In July 2022, the New York State Office of the Medicaid Inspector General...more

Local Law Amends New York City Charter and Establishes an Office of Healthcare Accountability

On June 8, 2023, the New York City Council passed a bill focused on healthcare accountability, with the goal of increasing access to healthcare services for New Yorkers. Entitled the Healthcare Accountability & Consumer...more

Medicare and Medicaid Providers, Take Note: New CMS Rules Require Health Care Workers to Be Fully Vaccinated by January 4, 2022

On November 4, 2021, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule (the “Rule”) requiring COVID-19 vaccination for staff at Medicare- and Medicaid-certified providers and suppliers.  The...more

Health Care Providers, Take Note: Biden Administration to Release Additional $25.5 Billion in COVID-19 Relief Funds

The Biden administration announced on September 10, 2021, the criteria for release of a $25.5 billion fourth tranche of COVID-19 relief funds. As with the other rounds of funding, the money is being made available to a wide...more

CMS Proposes to Increase Significantly Hospital Penalties for Price Transparency Violations

On July 19, 2021, the Centers for Medicare & Medicaid Services (“CMS”) issued a proposal that would significantly increase the fines that would be imposed on hospitals for price transparency violations. This proposal,...more

The CARES Act: Key Provisions for Health Care Providers

While the business and personal relief provisions of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) are understandably receiving the greatest coverage in the immediate aftermath of the bill’s signing,...more

CMS Issues Additional Blanket Waivers to Help Medicare Providers and Suppliers Meet Beneficiaries’ Health Care Needs During...

On March 13, 2020, when President Trump declared a national emergency under the Stafford Act, the Secretary of Health and Human Services utilized his authority to take particular actions, such as temporarily waiving or...more

Secretary Azar Urges Governors to Take Action to Lift Restrictions to Extend the Capacity of the Health Care Workforce

In response to the growing concerns of the capacity of the health care workforce as a result of the COVID-19 pandemic, on March 24, 2020 the Secretary of Health and Human Services, Alex Azar, issued a letter and associated...more

New York State Office of the Medicaid Inspector General Releases Guidance on Compliance Program Reviews

In the 1990s, as part of the Federal Sentencing Guidelines, the U.S. Sentencing Commission developed for the first time the criteria upon which it will view an organization’s compliance program to be “effective.” In October...more

Legislation to Curb Medicare and Medicaid Fraud Would Increase Cost and Compliance Burdens on Health Care Providers

On March 25, 2015, a bipartisan group of U.S. Senators reintroduced the Preventing and Reducing Improper Medicare and Medicaid Expenditures Act (“PRIME Act” or “Act”) following the lead of the U.S. House of Representatives,...more

“Next-Generation ACO” Model Is CMS’s Newest Effort to Encourage More ACO Risk

On March 10, 2015, the Centers for Medicare & Medicaid Services’ (“CMS’s”) Center for Medicare and Medicaid Innovation (“Innovation Center”) announced a demonstration project incorporating new risk models for reimbursement of...more

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