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Connecticut Supreme Court Addresses Contested Case Issue in Ruling on Certificate of Need Appeals

On July 25, 2023, the Connecticut Supreme Court issued an opinion in High Watch Recovery Center, Inc. v. Dept. of Public Health that addresses the subject of the right to file an appeal of a Certificate of Need (CON) decision...more

Health Law Diagnosis - July 2023 #2

On June 28, 2023, Connecticut Governor Ned Lamont signed Public Act No. 23-97, “An Act Concerning Health and Wellness for Connecticut Residents.” The Act includes a wide range of provisions aimed at supporting health care...more

Connecticut Governor Signs Legislation Implementing New Requirements for Hospitals and Nursing Home Facilities

Connecticut Governor Ned Lamont recently signed two important pieces of legislation that affect hospitals and certain Medicaid providers and programs. First, Public Act No. 23-39, “An Act Requiring Discharge Standards...more

Connecticut Governor Signs Bill Introducing Programs to Improve Maternal Health

On June 26, 2023, Connecticut Governor Ned Lamont signed Public Act No. 23-147, “An Act Protecting Maternal Health.” The Act makes various changes aimed at bolstering health care access and services for maternal and infant...more

Health Law Diagnosis - July 2023

Connecticut Governor Signs Health Care Bill Revising Connecticut’s Facility Fee Law - On June 27, 2023, Connecticut Governor Ned Lamont signed into law Public Act 23-171 entitled “An Act Protecting Patients and Prohibiting...more

Connecticut Expands Applicability of State False Claims Act

On June 26, 2023, Connecticut Governor Ned Lamont signed into law Public Act 23-129: “An Act Concerning Liability for False and Fraudulent Claims” (the Act). The Act expands application of Connecticut’s False Claims Act...more

Connecticut Health Care Bill Revises Provider-Payor Contracting Requirements to Address Competitive Concerns

On June 7, 2023, the Connecticut Legislature passed HB6669, “An Act Protecting Patients and Prohibiting Unnecessary Health Care Costs” (“the Act”), which includes a prohibition on certain contractual clauses in agreements...more

Connecticut Legislature Passes Law Limiting Physician, PA and APRN Non-Compete Agreements

On June 5, 2023, the Connecticut Legislature passed Public Act No. 23-97, “An Act Concerning Health and Wellness for Connecticut Residents” (“the Act”). Sections 13 through 15 of the Act make important changes to Connecticut...more

Connecticut Governor’s Health Care Bill Makes Important Changes to the Certificate of Need Process

On June 7, 2023, the Connecticut Legislature passed HB6669, “An Act Protecting Patients and Prohibiting Unnecessary Health Care Costs” (“the Act”). The Act implements legislative initiatives announced earlier this week that...more

Unanimous Supreme Court Endorses Subjective Belief Standard for False Claims Liability

On June 1, 2023, the U.S. Supreme Court issued a unanimous opinion in the highest-profile False Claims Act (FCA) case for many years, concluding that a party’s subjective belief as to whether it overcharged Medicare and...more

Health Law Diagnosis - DEA Extends Pandemic Telehealth Prescribing Flexibilities For Up To 18 Months

On May 9, 2023, the Drug Enforcement Administration (DEA) issued a temporary rule that extends pandemic-era flexibilities allowing prescribing of controlled substances based on a telehealth relationship, after receiving in...more

DEA Extends Pandemic Telehealth Prescribing Flexibilities For Up To 18 Months

On May 9, 2023, the Drug Enforcement Administration (DEA) issued a temporary rule that extends pandemic-era flexibilities allowing prescribing of controlled substances based on a telehealth relationship, after receiving in...more

HHS Seeks to Strengthen Protections of Reproductive Health Information with Proposed Changes to HIPAA

On April 12, 2023, the U.S. Department of Health & Human Services (HHS) released a Notice of Proposed Rulemaking (Proposed Rule) that seeks to enhance safeguards of reproductive health care information through changes to the...more

OCR Reminder: Pandemic-Era HIPAA Flexibilities Will End May 2023

On April 11, 2023 – one month in advance of the end of the COVID-19 public health emergency (PHE) on May 11, 2023 – the federal Office for Civil Rights (OCR) confirmed that various Notifications of Enforcement Discretion...more

OCR Reminder: Pandemic-Era HIPAA Flexibilities Will End May 11, 2023

On April 11, 2023 – one month in advance of the end of the COVID-19 public health emergency (PHE) on May 11, 2023 – the federal Office for Civil Rights (OCR) confirmed that various Notifications of Enforcement Discretion...more

Health Law Diagnosis - Stark Settlement Targeting Hospital and Physicians a Reminder for Health Care Organizations

On March 29, 2023, the Department of Justice’s (DOJ) Office for the Eastern District of Michigan announced a notable set of three settlements (collectively, the Settlement) in excess of $69 million dollars total with a...more

Stark Settlement Targeting Hospital and Physicians a Reminder for Health Care Organizations

On March 29, 2023, the Department of Justice’s (DOJ) Office for the Eastern District of Michigan announced a notable set of three settlements (collectively, the Settlement) in excess of $69 million dollars total with a...more

Health Law Diagnosis - CMS Issues Guidance for Providers on Waivers, Flexibilities and End of COVID-19 Public Health Emergency

The Centers for Medicare & Medicaid Services (CMS) recently issued a Fact Sheet (Fact Sheet) providing guidance on the impact of the end of the federal COVID-19 Public Health Emergency (PHE) on certain regulatory waivers,...more

CMS Issues Guidance for Providers on Waivers, Flexibilities and End of COVID-19 Public Health Emergency

The Centers for Medicare & Medicaid Services (CMS) recently issued a Fact Sheet (Fact Sheet) providing guidance on the impact of the end of the federal COVID-19 Public Health Emergency (PHE) on certain regulatory waivers,...more

As COVID-19 Emergency Waivers End, DEA Proposes to Expand Tele-Prescribing of Controlled Substances

On February 24, 2023, the federal Drug Enforcement Administration (DEA) issued a pair of proposed rules to make permanent certain “telemedicine flexibilities” related to the prescribing of controlled substances via telehealth...more

Health Law Diagnosis - January 2023

New York Governor Vetoes Act Prohibiting Establishment and Expansion of For-Profit Hospices - On December 23, 2022, New York Governor Kathy Hochul vetoed Assembly Bill Number A8472 “An Act To Amend The Public Health Law,...more

No More Reasonable Diligence? CMS Proposes to Change Standard for Identifying Medicare Overpayments to Align with False Claims Act

On December 27, 2022, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule (Proposed Rule) which proposes certain policy and technical changes to Medicare regulations, including a notable change to the...more

Advisory Opinion 22-19: OIG Warns That Proposed Drug Cost Subsidization Arrangement May Warrant Sanctions

On October 5, 2022, the Office of Inspector General (OIG) published Advisory Opinion 22-19 (Advisory Opinion), in which it determined that a proposed oncology drug discount arrangement could constitute grounds for the...more

DOJ Announces $900 Million Settlement Tied to Speaker Bureau Payments to Physicians

On September 26, 2022, the United States Department of Justice (DOJ) announced a $900 million settlement with pharmaceutical company Biogen Inc., which arose from alleged violations of the federal False Claims Act (FCA) and...more

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