For the year ending September 30, 2023, federal False Claims Act settlements and judgments exceeded $2.5 billion, much of which came from the health care industry. The largest, at over $487 million, stems from a finding by a...more
The No Surprises Act (“NSA”) became effective January 1, 2022 and protects consumers against surprise medical bills. However, a lesser known part of the NSA, called the Good Faith Estimate provisions, requires essentially all...more
HELPFUL HINTS -
Justice Department Reports More Than $8B In Alleged Fraud Related to COVID-19 Relief Programs -
The Washington Post reports, “Since the U.S. government first marshaled its historic economic response...more
3/17/2022
/ Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Infectious Diseases ,
Medicare ,
Surprise Medical Bills ,
Telehealth
On November 4, 2021, the Centers for Medicare & Medicaid Services (“CMS”) announced its interim final rule regarding vaccination requirements for eligible staff of certain health care providers. The rule, which becomes...more
11/5/2021
/ Biden Administration ,
Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Coronavirus/COVID-19 ,
Emergency Management Plans ,
Employer Liability Issues ,
Employer Mandates ,
Essential Workers ,
Health and Safety ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Workers ,
Infectious Diseases ,
Interim Final Rules (IFR) ,
Public Health Emergency ,
Vaccinations ,
Workplace Safety
Resources -
Effective Date Announced for New COVID-19 Safety Rule for Healthcare Providers -
OSHA's Emergency Temporary Standard imposes new COVID-19 requirements on healthcare providers. Employers must comply with...more
OSHA’s Emergency Temporary Standard imposes new COVID-19 requirements on healthcare providers. Employers must comply with most provisions by July 6, 2021....more
6/28/2021
/ Coronavirus/COVID-19 ,
Emergency Management Plans ,
Employer Liability Issues ,
Essential Workers ,
Health and Safety ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Workers ,
Infectious Diseases ,
New Guidance ,
OSHA ,
Personal Protective Equipment ,
Public Health ,
Workplace Safety
On December 2, 2020, the Centers for Medicare and Medicaid Services (“CMS”) finalized sweeping changes to the federal Physician Self-Referral Law, commonly known as the Stark Law. Many of the changes reflect CMS’ intent to...more
On October 9, 2019, the Centers for Medicare and Medicaid Services (“CMS”) proposed sweeping changes to the federal Physician Self-Referral Law, commonly referred to as the Stark Law. While many of the changes reflect CMS’...more
12/30/2019
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Comment Period ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Healthcare Reform ,
Medicaid ,
Medicare ,
Physician Compensation Arrangements ,
Physicians ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process ,
Stark Law
Lawmakers in both the United States House and Senate are considering two proposals to address unexpected, patient medical bills from out-of-network providers. Often referred to as “surprise medical bills” or “balance...more
Several studies show that the total cost of losing an employee can range from tens of thousands of dollars to 150 percent of the employee’s annual salary. There are also the “soft costs” of losing an employee, including lost...more
If the 2017 healthcare environment could be summed up in one word, it would be “uncertainty.” With the largely unexpected election of Donald Trump as President, the multiple, unsuccessful attempts by the Republican controlled...more
12/18/2017
/ Affordable Care Act ,
Bundled Payments ,
Centers for Medicare & Medicaid Services (CMS) ,
Cybersecurity ,
False Claims Act (FCA) ,
Health Care Providers ,
Health Insurance ,
Healthcare Reform ,
Medicaid ,
Medicare ,
Medicare Access and CHIP Reauthorization (MACRA) ,
Opioid ,
Pain Management Clinics ,
Physicians ,
Trump Administration
The following is the third installment of a three-part series discussing important provisions in physician employment agreements.
When a physician leaves a medical practice, especially if the physician stays in the area to...more
The following is the second installment of a three-part series discussing important provisions in physician employment agreements.
When a physician leaves a medical practice, especially if the physician stays in the area...more
The following is the first installment of a three-part series discussing important provisions in physician employment agreements.
When a physician leaves a medical practice, especially if the physician stays in the area...more
Since I began writing this year-end review in 2013, there have been some common themes – a shift to pay for quality and away from fee-for service, much of which has been brought about by the Affordable Care Act (ACA): efforts...more
12/12/2016
/ 60-Day Rule ,
Affordable Care Act ,
Alternative Payment Models (APM) ,
Centers for Medicare & Medicaid Services (CMS) ,
Data Breach ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
False Claims Act (FCA) ,
Health Care Providers ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Healthcare Fraud ,
HIPAA Breach ,
Hospitals ,
Implied Certification ,
Long Term Care Facilities ,
Medicaid ,
Medicare ,
Medicare Access and CHIP Reauthorization (MACRA) ,
MIPS ,
OIG ,
Overpayment Recovery Time Limits ,
PHI ,
Physicians ,
Popular ,
Premiums ,
Provider Payments ,
Quality Payment Program (QPP) ,
Trump Administration ,
Universal Health Services Inc v United States ex rel Escobar ,
Value-Based Payments
Since the enactment of the net investment income tax ("NIIT") in 2012, physicians and other taxpayers owning multiple business interests have had to make educated choices based upon accounting projections and SWAGS when...more
In an effort to review and examine compliance with the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations ("HIPAA"), the Department of Health and Human Services Office for Civil...more
Driven by Federal Health Care Reform and a desire to remain independent of hospitals and health care systems, physician groups are actively exploring different collaborative and alignment options, including the formation of...more
On January 17, 2013, the Department of Health and Human Services (“HHS”) released its long awaited final HIPAA rule, which significantly expands certain obligations for healthcare providers and their business associates (the...more
2/5/2013
/ Business Associates ,
Compliance ,
Data Breach ,
Decedent Protection ,
Enforcement ,
Fundraisers ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HITECH Act ,
Immunization Records ,
Marketing ,
Notice Requirements ,
Patient Rights ,
PHI ,
Privacy Policy ,
Privacy Rule ,
Subcontractors ,
Third-Party