The End of COVID Waivers and Exceptions: What Now?
CF on Cyber: An Update on the Florida Security of Communications Act (FSCA)
Podcast: CMS and OIG Final Rules for Innovating Your Value-Based Payment Program - Diagnosing Health Care
Updates to Paid Leave Requirements Under FFCRA
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
[WEBINAR] Exploring the CPRA’s Investigatory Privilege
Jones Day Talks Health Care: The Eliminating Kickbacks in Recovery Act
On April 23, the Federal Trade Commission (FTC) approved a long-anticipated final rule that will effectively ban the use of noncompete clauses by employers, with a few limited exceptions....more
On July 15, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System proposed rule...more
The Occupational Safety and Health Administration (OSHA) issued the COVID-19 Healthcare Emergency Temporary Standards (ETS) on June 10, 2021. The ETS applies to workplace settings where professional healthcare...more
On November 20, 2020, the Centers for Medicare and Medicaid Services and Office of Inspector General released final rules amending the regulations to the Stark Law and the Anti-Kickback Statute and Beneficiary Inducement...more
On December 2, 2020, CMS and OIG finished a two-year sprint to modernize the Stark and Anti-Kickback (AKS) regulations to remove barriers to value-based care and incentivize patient-centered care coordination....more
Across the country, hospitals and healthcare providers are facing an unprecedented surge of patients with COVID-19 symptoms while continuing to care for patients with other medical conditions. Responding adequately to the...more
While we are waiting for final disposition of the AKS Safe Harbors and Stark Exceptions proposed in October of 2019, since the comment period expired December 31, 2019 and final rules have not been issued, I thought we should...more
What larger healthcare goals are fueling the proposed revisions to AKS and Stark? What safe harbors and exceptions are introduced in the proposed rules? And what would the potentially transformational changes mean for...more
In this week's episode, Lindsey Rogers-Seitz forecasts a number of critical issues spanning the health care industry that are likely to be points of focus in the coming year. Among these issues, Ms. Rogers-Seitz discusses the...more
On October 9, 2019, the Centers for Medicare and Medicaid Services (CMS) released two proposed rules: Modernizing and Clarifying the Physician Self-Referral Regulations and Fraud and Abuse; Revisions to Safe Harbors under the...more
On October 9, 2019, the U.S. Department of Health and Human Services released proposed changes to the Ethics in Patient Referrals Act (the “Stark Law”), as well as the Medicare and Medicaid Anti-Kickback Statute (the...more
On October 9, 2019, the Department of Health & Human Services (HHS) announced significant changes to the Anti-Kickback Statute (AKS) and the Physician Self-Referral Law (known as the Stark Law) through proposed rules issued...more
The Department of Health & Human Services’ (HHS) proposed changes to the Stark Law, the Anti-Kickback Statute, and the Civil Monetary Penalty Law, released today as part of the Regulatory Sprint to Coordinated Care, would...more
Florida Governor Ron DeSantis recently signed House Bill 369, Chapter No. 2019-159, Laws of Florida, which became effective on July 1, 2019. The primary focus of the bill relates to substance abuse services. For example, the...more
The ONC finally released its long-awaited proposed rule to implement the “information blocking” prohibition of the 21st Century Cures Act by identifying conduct that is not information blocking. If finalized, ONC’s proposed...more
With Advisory Opinion 17-04, issued August 24, 2017, the U.S. Department of Health and Human Services, Office of Inspector General (OIG) adds to the ever-growing number of favorable advisory opinions regarding an agreement...more
Hospitals operating in regions affected by the recent hurricanes and other natural disasters may be able to obtain temporary regulatory relief. During times of disasters and emergencies, CMS can provide some flexibility...more
With change, breaking news, and uncertainty dominating the legal concerns of health care providers on a federal level, it remains important to review and refresh on state-level concerns and legal rules. This is especially...more
ALSO IN THE NEWS: CMS Extends Deadline for Hardship Exception Applications – On February 26, 2016, CMS updated its online instructions for submitting a hardship exception application to reflect that hardship exception...more
On January 22, CMS posted a revised application and instructions for a hardship exception from the Meaningful Use program penalties in 2015. Under the new, streamlined application process, which CMS says is a temporary...more
The Stark Law has been updated effective January 1, 2016 in ways that may affect your medical practice and hospital relationships. Among other things, these updates add two new exceptions to the referral prohibition, relax...more
The Centers for Medicare & Medicaid Services (CMS) recently released a new exception to the Physician Self-Referral Law (the “Stark Law”) intended to expand access to primary care and mental health services (the “NPP...more
In a development that is limited in scope but still welcomed by hospitals, the proposed 2016 Physician Fee Schedule proposes a number of new exceptions to the physician self-referral or Stark law and other refinements that...more
The Court of Appeal reaffirms the qualified nature of legal professional privilege. In the recent case of R v Edward Brown (formerly Latham) the Court of Appeal held that it was appropriate, in certain circumstances, to...more
In July 2015, CMS released proposals to provide several new Stark Law exceptions and to clarify issues regarding existing exceptions. Over the next few days, I will post comment on what I consider the most significant new...more