A trifecta federal agency approach to expansion efforts related to health reimbursement arrangements (“HRAs”) occurred on October 29, 2018. The Departments of Treasury, Health and Human Services, and Labor (collectively, the “Departments”) jointly announced proposed HRA regulations, effective for…
HIPAA, as amended by HITECH, imposes significant requirements on those persons or entities who constitute a business associate as a result of their access to protected health information in the performance of services on behalf of a covered entity.[1]
For example, a business associate could be a…
On November 8, 2018, the Centers for Medicare and Medicaid Services ("CMS") published a proposed rule aimed at Medicaid managed care. CMS indicated its intentions to streamline the managed care framework and relieve regulatory burdens created in the existing managed care regulations, which were…
Governor Eric Holcomb signed Senate Enrolled Act 221 (“SEA 221”) into law on March 22, 2018, which updated INSPECT requirements for practitioners with a controlled substance registration (“CSR”) in Indiana. Notably, several of the bill’s requirements are effective January 1, 2019.
Under SEA 221, all…
An ABC television crew was permitted to film on the premises of three Boston-area teaching hospitals, Boston Medical Center (“BMC”), Brigham and Women’s Hospital (“BWH”), and Massachusetts General Hospital (“MGH”). However, the three healthcare providers failed to first obtain patient…
On September 17, 2018, the Centers for Medicare and Medicaid Services "CMS" published a proposed rule to reduce burdensome regulations affecting healthcare providers as part of its "Patients Over Paperwork" initiative which began in 2017. More information about the Patients Over Paperwork…
On October 4, 2018, the Indiana Family and Social Services Administration published a proposed rule (“LSA #18-251”) that overhauls its Medicaid program integrity requirements. LSA #18-251 revises, clarifies, and adds new provisions affecting nearly all business aspects for Indiana Medicaid…
On July 10, 2018, President Trump signed an Executive Order (“EO”) that altered the manner in which Federal Administrative Law Judges (“ALJ”) are selected for service from competitive examination and competitive service selection procedures to agency appointments. The changes in the EO were…
On August 7, 2018, the Office of Inspector General (OIG) issued Advisory Opinion No. 18-08, which evaluated a proposal by six government-operated fire departments (the “Departments”) to enter into a mutual aid agreement to provide unscheduled, backup emergency ambulance services (“Backup Services”)…
As reported in CMS’s MLNConnects (click here for release), CMS recently proposed significant regulatory changes that would reduce the burden of Medicare paperwork and thereby increase the amount of time that physicians and other clinicians can spend with their patients. The proposed rules are…
Whether you are the Privacy Officer, the Security Officer, or both, the question remains the same. When was the last time you scheduled a "walk through" of your work space for the sole purpose of looking into the "eyeballs" of your personnel and finding out what they are really doing (or not doing)…
The Joint Commission (“JC”) recently released a new Standards FAQ (“FAQ”) setting forth guidelines that should be followed when physicians or other licensed independent practitioners (“LIPs”) use documentation assistants (referred to herein as “scribes”) to assist with documentation. In the FAQ,…
