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Estate Planning During Divorce (Part 2)
It pays to look closely. Buried deep within a 205-page and 1230-page Federal Register final rules publication, the Centers for Medicare & Medicaid Services (“CMS”) initiated impactful changes for pharmacies and Durable...more
Continuing a now annual tradition, the Centers for Medicare & Medicaid Services (CMS) has included expansions and enhancements to its authorities to deny enrollment or revoke a provider’s Medicare billing privileges...more
The Centers for Medicare & Medicaid Services (CMS) requires Medicare providers and suppliers to keep their enrollment information up to date at all times. Changes in this information can affect claims processing, payment...more
Across the U.S., many large, non-profit health systems, hospitals, and healthcare providers pay little, if any, property taxes. The long-held property tax exemption is under attack from revenue-hungry tax authorities. Jared...more
As a doctor, allegations of medical malpractice or other unlawful or unethical conduct can have wide-ranging implications. In addition to facing civil liability and the prospect of a significant increase in your medical...more
Editor’s Note: The average cost of a Telephone Consumer Protection Act (TCPA) settlement is estimated at $6.6 million—and healthcare is among the top three industries being targeted for TCPA litigation. Though its sponsors in...more
CMS recently finalized the most significant changes to enrollment since the 2006 enrollment rules were initially adopted. Overview of the New Rule - In its "Program Integrity Enhancements to the Provider Enrollment...more
The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more
Yesterday, a final rule issued by the Centers for Medicare & Medicaid Services (CMS) establishing new enforcement initiatives aimed at removing and excluding previously sanctioned entities from Medicare, Medicaid, and the...more
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry. ...more
As part of an increasing trend towards regulation of behavioral health, a pair of new laws have been adopted that will impact certain California behavioral health providers and laboratories, with two proposed companion laws...more
On September 5, 2019, the Centers for Medicare & Medicaid Services (CMS) announced a final rule expanding CMS’ authority to deny or revoke enrollment in the Medicare program as a result of “bad actor” affiliations. Providers...more
On September 5, 2019, the Centers for Medicare and Medicaid Services (“CMS”) released a final rule with comment period entitled, “Program Integrity Enhancements to the Provider Enrollment Process” (the “Final Rule”). The...more
The Centers for Medicare & Medicare Services (CMS) recently proposed sweeping changes that would permit the denial of a Medicare enrollment application or a billing privilege revocation for professionals eligible to...more
CMS revised its policy guidance regarding adverse action reporting requirements once again in the Medicare Program Integrity Manual (MPIM) Transmittal 865. This guidance is arguably inconsistent with the regulations and with...more
In response to the opioid crisis, the Drug Enforcement Administration (DEA) is cracking down on pharmacies, pharmacists, and prescribers by leveraging an old enforcement weapon: revocation of controlled substance...more
Eversheds Sutherland is pleased to send you its fifth annual REDIAL: 2018 TCPA YEAR-IN-REVIEW – ANALYSIS OF CRITICAL ISSUES AND TRENDS IN TCPA COMPLIANCE AND LITIGATION. Inside this digital edition, you will find our...more
On June 1, 2018, CMS issued further guidance for reporting and reviewing final adverse legal actions (ALAs) in provider enrollment applications. In Transmittal 797, which replaces Transmittal 784 to the Medicare Program...more
This article addresses the Court’s reversal of over a decade of confusion regarding autodialers. The TCPA defines an autodialer (automatic telephone dialing system, or ATDS) as “equipment which has the capacity (a) to store...more
Here, we address one significant component of the decision: the D.C. Circuit’s confirmation that consumers may revoke consent to call by any reasonable means but with the qualification that parties may be able to contract...more
Here, we examine the D.C. Circuit’s reversal of not simply the one-call safe harbor for reassigned numbers imposed by the FCC’s 2015 TCPA ruling but also the Commission’s treatment of reassigned numbers as a whole. ...more
In a watershed case, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit) unwound key components of the controversial 2015 ruling by the Federal Communications Commission (FCC or Commission)...more
On July 10, 2015, the Federal Communications Commission (“FCC” or “Commission”) released a Telephone Consumer Protection Act (“TCPA”) Declaratory Ruling and Order (“TCPA Declaratory Ruling and Order” or “Order”) offering...more
Recently, we have noticed an alarming increase within the Spilman footprint of revocations by the Centers for Medicare & Medicaid Services ("CMS") of physicians' Medicare billing privileges. In particular, CMS has been...more
In 2014, CMS issued a final rule related to 42 CFR 424.535, which gave CMS expanded authority to impose penalties on providers. Although the rule is several years old, the first version published in 2006, the rule has been...more