News & Analysis as of

Hospitals Civil Monetary Penalty

Mitchell, Williams, Selig, Gates & Woodyard,...

Fund Eligibility/Storage Tank Enforcement: Tennessee Department of Environment and Conservation and Hendersonville Hospital Enter...

The Tennessee Department of Environment and Conservation (“TDEC”) and Henderson Hospital Corporation (“HHC”) entered into an August 23rd Settlement Agreement and Order (“Agreement”) addressing alleged violations of the...more

Spilman Thomas & Battle, PLLC

The Health Record - Healthcare Law Insights, Issue 4, August 2024

Welcome to our fourth issue of The Health Record - our healthcare law insights e-newsletter. In this edition, we address a variety of topics including a recent SCOTUS ruling and the potential impact on CMS, issues of patient...more

King & Spalding

OIG Updates Fraud and Abuse Authorities FAQs

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On July 8, 2024, OIG updated the Frequently Asked Questions on its website, adding four new questions and answers to its General Questions Regarding Certain Fraud and Abuse Authorities...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Thousand Oaks, California Medical Center Enter into...

The United States Environmental Protection Agency (“EPA”) and Los Robles Hospital Medical Center (“ Los Robles”) entered into a March 27th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of the Federal...more

Health Care Compliance Association (HCCA)

In Biggest Stark-Based FCA Settlement Ever, Indiana Hospital Pays $345M, Has Unusual CIA

Community Health Network (CHN) in Indiana has agreed to pay $345 million to settle false claims allegations that it paid over-the-top salaries to hundreds of physicians and rewarded them for their referrals in violation of...more

Holland & Hart LLP

Avoiding EMTALA Penalties

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The Emergency Medical Treatment and Active Labor Act ("EMTALA") provides that if a patient comes to a hospital or hospital-owned urgent care center, the hospital and relevant on-call physicians must provide an appropriate...more

Holland & Knight LLP

EMTALA Patient Education Initiative Launched by HHS and CMS

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The U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) have started a new effort to educate the public about the Emergency Medical Treatment and Labor Act (EMTALA)....more

Harris Beach PLLC

OIG Approves MediGap Insurer’s Use of PHO Network Hospitals to Offer Discounts on Inpatient Deductibles

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The Office of Inspector General (OIG) recently issued two identical favorable OIG Advisory Opinions, concluding that, although the proposed arrangement (“Proposed Arrangement”) between a Medicare Supplement insurer (“MediGap...more

Amundsen Davis LLC

Hospitals Beware: What to Expect During an EMTALA Investigation

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The Centers for Medicare and Medicaid Services (CMS) has increasingly focused its efforts on investigating hospital emergency departments for potential violations of the Emergency Medical Treatment and Labor Act (EMTALA),...more

King & Spalding

CMS Issues Civil Monetary Penalties for Hospital Price Transparency Non-Compliance

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Last month, CMS issued three civil monetary penalty (CMP) notices for violations of the hospital price transparency regulations (HPT Rule), which requires hospitals to make public the standard charges of the items and...more

McGuireWoods Consulting

CMS Tightens Hospital Price Transparency Enforcement Measures

On April 26, the Centers for Medicare and Medicaid Services (CMS) strengthened its enforcement of the hospital price transparency rule by implementing three new enforcement measures. These include...more

King & Spalding

OIG Issues Favorable Advisory Opinion Regarding Health System’s Use of Nurse Practitioners for Services Traditionally Performed by...

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On December 19, 2022, OIG posted Advisory Opinion 22-20, responding to a request submitted by an acute care hospital (the Hospital) regarding the utilization of its employed nurse practitioners (NPs) to perform services that...more

Health Care Compliance Association (HCCA)

New Hampshire Health System Pays $2.1M in CMP Settlement Over Diagnostic Test Orders

Report on Medicare Compliance 31, no. 35 (September 26, 2022) - For the third time in about 2 1/2 years, hospitals or other providers that are part of Dartmouth-Hitchcock Health, a large health system in New Hampshire,...more

Proskauer - Health Care Law Brief

Health Care Providers on Alert: Two Hospitals Penalized for Continuous Noncompliance with the Hospital Price Transparency Rule

We previously discussed the requirements of the Hospital Price Transparency Rule (“Rule”) on health care providers and health plans, as well as CMS’s proposal to increase penalties for a hospital’s failure to comply with the...more

Husch Blackwell LLP

CMS Imposes First Price Transparency Rule Penalties

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The Price Transparency Rule (the Rule) became effective on January 1, 2021. By October 2021, the Centers for Medicare & Medicaid Services (CMS) had issued warnings to over 300 hospitals deemed not in compliance with the...more

Baker Donelson

CMS Proposes Changes to Hospital Price Transparency Rules, Increased Penalties

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On August 4, 2021, the Centers for Medicare & Medicaid Services (CMS) published proposed changes to enforcement of the hospital price transparency rules that went into effect earlier this year. The proposed changes, part of...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 30, Number 28. News Briefs: August 2021

Report on Medicare Compliance 30, no. 28 (August 2, 2021) - CMS has not fined any hospitals yet for noncompliance with price transparency requirements, a spokesperson tells RMC. “In April 2021, CMS began issuing warning...more

Steptoe & Johnson PLLC

CMS Continues Its Focus on Hospital Pricing Transparency

The Centers for Medicare & Medicaid Services’ (“CMS”) message this year has been consistent – hospitals need to comply with CMS’ Hospital Transparency Rule. This rule requires hospitals and health systems to disclose a...more

Manatt, Phelps & Phillips, LLP

[Webinar] Navigating the No Surprises Act: Your Guide to Requirements, Challenges & Compliance - August 2nd, 1:00 pm - 2:00 pm ET

What New Obligations Does the No Surprises Act Impose on Health Systems and Health Plans—and How Can You Prepare for the Impact? Learn the Answer at a New Manatt Webinar. The No Surprises Act (NSA)—set to take effect...more

Bricker Graydon LLP

Hospital price transparency rule penalties may increase

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The Centers for Medicare and Medicaid Services (CMS) has proposed increasing the penalty for violations of the hospital price transparency rule in the proposed outpatient pay rule announced on July 19, 2021. Hospitals...more

Foley & Lardner LLP

Hospital Price Transparency: CMS Issues Proposed Rule to Increase Penalties for Larger Hospitals Violating Disclosure Requirements

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On July 19, 2021 the Centers for Medicare and Medicaid Services (CMS), as part of proposed rule covering a variety of subjects, including Medicare Hospital Outpatient and Ambulatory Surgery Center PPS modifications, issued a...more

Health Care Compliance Association (HCCA)

Radiation Therapy Provider Pays $3.6M in CMP Settlement; OIG: 25 CPT Codes ‘Involved’

Report on Medicare Compliance 30, no. 22 (June 14, 2021) - A Colorado radiation therapy provider has agreed to pay $3.569 million in a civil monetary penalty settlement with the HHS Office of Inspector General (OIG). ...more

Foley & Lardner LLP

Bipartisan Leadership of House Committee of Energy and Commerce and its Health Subcommittee Urge HHS Secretary Becerra to...

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By letter dated April 13, 2021 (Letter), the Democrat and Republican leadership of the House Committee on Energy and Commerce and its Subcommittee on Health, wrote United States Health and Human Services Secretary, Xavier...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 30, Number 11. News Briefs: March 2021 #2

Report on Medicare Compliance 30, no. 11 (March 22, 2021) - University Medical Center of Southern Nevada has agreed to pay $128,820 in a civil monetary penalty settlement that stemmed from a self-disclosure. According to...more

Faegre Drinker Biddle & Reath LLP

Fifth Circuit Decision Motivates Covered Entities to Appeal Unreasonable Enforcement Outcomes

The United States Court of Appeals for the Fifth Circuit (the “Court”) vacated a $4,348,000 civil monetary penalty (“CMP”) imposed by the U.S. Department of Health and Human Services’ Office for Civil Rights (“HHS-OCR”) in...more

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