Did your company have a HIPAA breach affecting less than 500 individuals in calendar year 2016 that has not yet been reported to HHS? If so, the deadline for submission of any breach notifications to HHS is March 1, 2017.
HIPAA requires that covered entities maintain a log or other documentation of…
The Health and Human Services Office of Inspector General (“OIG”) finalized Regulations on January 12, 2017, that revise and clarify Federal authorities governing a health care provider’s participation in and exclusion from a Federal health care program, i.e., Medicare and Medicaid. These changes…
On January 18, 2017, the Substance Abuse and Mental Health Services Administration (“SAMHSA”) published a Final Rule that updates the confidentiality requirements and provisions to improve the exchange of information of patients seeking treatment for a substance abuse disorder of 42 C.F.R. Part 2…
On January 27, 2017, CMS issued final guidance regarding implementation of its Medicare Outpatient Observation Notice (MOON) program. The MOON informs all Medicare beneficiaries (both traditional fee-for-service and Medicare Advantage) when they are an outpatient receiving observation services, and…
The Bipartisan Budget Act of 2015 (“Section 603”) made waste of many hospitals’ plans for off-campus provider-based practice locations. Notwithstanding, a final reprieve for certain provider-based facilities is the 21st Century Cures Act’s “mid-build” exception, which creates an exception to…
On January 30, 2017, Indiana’s Family and Social Services Administration (“FSSA”) published Bulletin BT201710 announcing that the Indiana Health Coverage Programs (“IHCP”) have set Monday, February 13, 2017, as the new implementation date for replacing the current information system, IndianaAIM,…
The U.S. Department of Health and Human Services Office of Civil Rights and The Office of the National Coordinator for Health Information Technology recently published a new fact sheet entitled “Permitted Uses and Disclosures: Exchange for Health Oversight Activities.” This fact sheet provides…
The FDA continues to monitor and assess potential cybersecurity vulnerabilities associated with radio frequency (“RF”) enabled implantable devices. The FDA recently reviewed St. Jude Medical’s Merlin@home Transmitter and software patch – an implantable cardiac device – to determine any…
On January 3, 2017, the Indiana Department of Insurance (“Department”) issued Bulletin 235, titled “Interest Rate for Failure to Pay a Clean Claim,” clarifying the interest rate calculated on clean claims pursuant to Indiana Code Sections 27-8-5.7 and 27-13-36.2 (“Clean Claims Laws”). Under the…
On January 9, 2017, the Office of Inspector General for the Department of Health and Human Services (the “OIG”) released a thirty-two page report detailing its review of NorthShore University HealthSystem’s (“NorthShore”) Medicare compliance during 2013 and 2014, as part of a series of hospital…
On January 13, 2017 CMS published a comprehensive final rule revising the conditions of participation (“COPs”) that home health agencies (“HHAs”) must abide by in order to participate in Medicare and Medicaid programs. Through the changes to these rules, CMS seeks to achieve broad-based, measurable…
On January 9, 2017, the United Stated Department of Health and Human Services, Office of Civil Rights (HHS) announced that it has issued its first enforcement action with a healthcare entity due to the entity’s alleged failure to notify affected individuals, HHS and media outlets of a breach of…
