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Federally Qualified Health Center Provider Referral Contracts and Arrangements

Federally Qualified Health Centers (FQHCs) are required to provide all required primary, preventive, and enabling health services as well as additional health services as appropriate and necessary – either directly or through...more

OIG Permits Health System and Federally Qualified Health Center Look-Alike Collaboration Agreement Restructuring Which Includes...

In OIG Advisory Opinion 22-17, the U.S. Department of Health and Human Services (H.H.S.) Office of Inspector General (OIG) analyzed a proposal whereby a regional non-profit health system would forgive debt owed by a federally...more

The OIG Issues Special Fraud Alert Identifying "Suspect" Telemedicine Contract Arrangements

On July 20, 2022, the United States Department of Justice (the DOJ) announced charges against multiple defendants alleging fraudulent schemes (including telemedicine arrangements) totaling more than $1.2 billion. That same...more

OIG Advisory Opinion 22-08 Permits Federally Qualified Health Center To Provide Smartphones to Patients to Promote Access to...

Telehealth—the provision and coordination of healthcare remotely by means of telecommunications technology—is now an essential tool in the delivery of health care services. The COVID-19 pandemic created an incentive for...more

California Appellate Court Rules Federally Qualified Health Center Outreach Expenses Don't Qualify For Cost-Based Reimbursement

Family Health Centers of San Diego (Health Center) operates a federally qualified health center (FQHC) that has 49 locations throughout San Diego County, California, and provides a comprehensive range of primary and...more

New OIG Guidance Permits Federally Qualified Health Centers to Offer Remote Patient Monitoring, Big-Box Store Gift Cards, and...

Federally Qualified Health Centers (FQHCs) deliver care to some of the nation's most vulnerable individuals and families, including federal Medicare and Medicaid health care program beneficiaries. As safety net providers,...more

Attention Pharmacies and Prescribers: New California Controlled Substances Prescription Form and CURES Reporting Requirements Are...

Compliance with prescription drug controlled substances prescribing and dispensing rules is essential for pharmacies and prescribers, as penalties for non-compliance are severe and can result in State Board of Pharmacy and...more

Federally Qualified Health Center Agrees to Settlement for Failure to Implement

As detailed in a press release from the U.S. Department of Health and Human Services (HHS), "Metropolitan Community Health Services, doing business as Agape Health Services (Metro), has agreed to pay $25,000 to the U. S....more

OPA Program Update 2020 Highlights Changes to 340B Program Registration and Recertification Requirements

On July 20, 2020, the Health Resources and Services Administration's (HRSA) Office of Pharmacy Affairs (OPA) issued the OPA Program Update 2020. In addition to adopting new Covered Entity registration and recertification...more

Guidance for Protecting Pharmacy Staff and Customers from COVID-19

Employees concerned about their workplace safety amidst the COVID-19 pandemic recently filed a legal action against their employer (Smithfield Foods) seeking a court order that would require the company to comply with Centers...more

CMS Revises and Updates Requirements for the Programs of All-Inclusive Care for the Elderly (PACE)

The Centers for Medicare & Medicaid Services (CMS) recently revised regulations (the "Regulations") for the Programs of All-Inclusive Care for the Elderly (PACE), making significant changes to ownership restrictions,...more

Attention Health Care Providers: California Adopts Restricted Knox-Keene Licensure/Exemption Requirements

The California Department of Managed Health Care (the "DMHC"), which regulates Health Care Service Plans, recently adopted a regulation regarding general licensure requirements for health care providers ("Entities") that...more

Health Care Organizations Should Take Heed of New HHS Cybersecurity Guidance

Cybersecurity is a significant and growing compliance risk for health care organizations. If your organization fails to protect patients from cybersecurity risks, the result could be serious fines and penalties for...more

Small Breaches Matter Too: OCR Broadens HIPAA Breach Investigations

The Regional Offices of the Department of Health and Human Services Office for Civil Rights (OCR) already investigate every reported Health Insurance Portability and Accountability Act (HIPAA) breach affecting 500 or more...more

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