A former Patient Information Coordinator (Patient Coordinator), previously employed with UPMC and its affiliate, Tri Rivers Musculoskeletal Centers (TRMC) in Mars, Pennsylvania, pleaded guilty to a charge of wrongfully disclosing health information, in violation of the Health Insurance Portability…
In an opinion issued on February 25, 2019, the Illinois Appellate Court confirmed that a not-for-profit hospice provider was not entitled to a charitable use property tax exemption because it was not exclusively engaged in charity care. See Midwest Palliative Hospice and Care Center v. Constance…
A new year means “New Year’s Resolutions.” Many people commit to financial resolutions for 2019, whether it is eliminating debt or creating a monthly budget. Unfortunately, they neglect their estate plans. Adding estate planning to your resolutions is important for a variety of reasons, whether you…
The Office of Medicaid Policy and Planning finalized a rule impacting applied behavioral analysis (ABA) Therapy services effective March 1, 2019. Affected services providers should review and revise business policies and practices to accommodate these new changes as applicable. Note that the final…
The process for dealing with Medicare or Medicaid overpayments is essential to any health care organization. The mishandling of overpayments can result in substantial corporate liability, including potential claims of wrongful retention of overpayments in violation of the False Claims Act. Every…
The Health and Human Services Office of Civil Rights (“OCR”) recently entered into its final Resolution Agreement of 2018 to resolve HIPAA allegations involving Cottage Health, a California health system that serves patients throughout the state. Cottage Health provided notice of breaches of…
The OIG recently published favorable guidance in Advisory Opinion No. 19-01 regarding the waiver of cost-sharing amounts for charitable pediatric care in limited circumstances (“Arrangement”). While OIG concluded that the pediatric clinic’s Arrangement could potentially generate prohibited…
In October of 2018, Congress passed the SUPPORT for Patients and Communities Act (“SUPPORT Act”), a measure attempting to address the opioid epidemic at the national level. Two sections of the SUPPORT Act specifically mandate changes that will likely affect most providers, including the electronic…
The Health and Human Services’ Office of Inspector General (“OIG”) has published an annual Work Plan for many years, which typically reported on current OIG audits and evaluations, in addition to certain legal and investigative efforts, that concerned compliance issues across the many industry…
In furtherance of the many safeguards, both the HIPAA Privacy regulations, 45 CFR 164.530(b)(1), and the HIPAA Security regulations, 45 CFR 164.308(a)(5), require orientation and ongoing training programs for the Workforce. 45 CFR 160.103 defines “Workforce” to include all employees, volunteers,…
In 2015, California enacted the “Reproductive Freedom, Accountability, Comprehensive Care, and Transparency Act” (the “FACT Act”) requiring pregnancy centers to post notices in their facilities advising women that the State of California provided free or low-cost family planning services and…
The Indiana Family and Social Services Administration (“FSSA”) published a proposed rule that affects Medicaid reimbursement for legend and non-legend drugs. A public hearing about this rule is schedule for January 31, 2019 at 10:00am EST, and the FSSA is accepting public comments through that…
