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Search OptionsInsightsCMS Reminder Regarding Services Rendered by Hospitals to Patients Staying in Other Facilities
The Centers for Medicare and Medicaid Services (“CMS”) recently issued guidance (MLN Matters SE17033 – Revised) re-emphasizing that Medicare should not pay an acute care hospital for services furnished to a Medicare beneficiary, when the beneficiary… 
Bipartisan Budget Act of 2018
As reported in our previous Employee Benefits ALERT, the Tax Cuts and Jobs Act provided several changes affecting qualified retirement plans. On February 9, 2018, Congress passed, and President Trump signed into law, the “Bipartisan Budget Act of… 
IRS Reduces 2018 Limits for Health Savings Accounts and Adoption Credits
The Tax Cuts and Jobs Act signed by President Trump on December 22, 2017 included a requirement that modifications of cost-of-living adjustments be made to certain statutory limits based on the Chained Consumer Price Index for All Urban consumers… New Disability Claims Final Regulations - Effective April 1st!
The Department of Labor (DOL) expanded the claims procedures for disability benefits in final regulations issued on December 19, 2016 with a delayed effective date of April 1, 2018 (“Final Regulations”). The Final Regulations expand the current… Court Determines Debtor's Correct Name on Driver's License for UCC-1 Financing Statement
On February 1, 2018, the US Bankruptcy Court for the Southern District of Georgia in In re: Kenneth R. Pierce found that the printed name on the debtor’s driver’s license was the name that was important for Uniform Commercial Code (UCC) security… CMS Reminds Providers to Report Changes in Ownership
CMS’ recent MLN Connects e-Newsletter reminds providers of their obligation to report changes in ownership to CMS and highlighted the 2016 Office of Inspector General (“OIG”) study that revealed providers may not be properly reporting changes in… 
Continuing HIPAA Obligations After a Business Ceases
In a recent announcement by the U.S. Department of Health and Human Services (“HHS”), Office of Civil Rights (“OCR”), the OCR was clear to make a point that just because a business closes during an OCR investigation, does not mean that the business’… 
OIG Approves of Hospital-Physician Gainsharing Arrangement, But Details Prove Critical
A December 2017 Office of Inspector General (“OIG”) Advisory Opinion favors a gainsharing arrangement whereby a hospital will share with specific neurosurgeons a percentage of the hospital’s cost savings from spinal surgeries performed at the… 
Passing of Bi-Partisan Budget Act Affects Medicaid Payments
On February 9, 2018, both the House and the Senate voted to pass, and President Trump signed into law, the Bi-Partisan Budget Act of 2018 (the “Act”, House Resolution 1892). Most notably this Act extends federal appropriations through March 23,… 
Recent OCR Resolution Agreement and Corrective Action Plan ... Lessons Learned
The Health and Human Services’ Office of Civil Rights (“OCR”) recently entered into yet another Resolution Agreement after investigating a serious breach incident involving the electronic protected health information (“e-PHI”) of over 2 million… 
Ability to Prescribe Buprenorphine Expanded to Mid-Level Practitioners
On January 23, 2018, the U.S. Drug Enforcement Administration (“DEA”) issued a final rule announcing another step to increase opioid addiction treatment.[1] Effective January 22, 2018, nurse practitioners (“NP”) and physician assistants (“PA”) are… 
OIG Settles Cases Involving Allegations of EMTALA Violations
In December 2017, the Office of Inspector General (“OIG”) entered into settlement agreements with four hospitals to resolve allegations of violations of the Emergency Medical Treatment and Labor Act (“EMTALA”).[1] EMTALA requires hospitals to… 
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