Insights |
Search OptionsHealth CareOIG Advisory Opinion on Free or Reduced-Cost Lodging and Meals
On March 10, 2017 the Department of Health and Human Services, Office of Inspector General (“OIG”) published Advisory Opinion No. 17-01 regarding a hospital system’s proposal to provide free or reduced-cost lodging and meals to certain financially needy patients (“Proposed Arrangement”). The OIG… President's Proposed Budget Makes Deep Cuts, But Seeks Increases To Medicare Fraud Fight
President Trump’s March 16 “America First: A Budget Blueprint to Make America Great Again,” proposes to cut $15.1 billion in Department of Health and Human Services (“HHS”) spending, representing a nearly 18% reduction in annual spending.[1] The cuts target many entrenched programs and grants,… HIPAA Business Associates ... How Do I Know Thee?
HIPAA, as amended by HITECH, imposes significant requirements on those persons or entities who qualify as a business associate (BA) as a result of their access to protected health information (PHI) in the performance of services on behalf of a covered entity (CE). For example, a BA could be a third… HHS OIG Adds New Authorities to the Anti-Kickback Statute and Civil Monetary Penalties Law
The Health and Human Services Office of Inspector General (“OIG”) recently finalized new regulations (“Regulations”) impacting the anti-kickback statute (“AKS”) safe harbors and civil monetary penalties law (“CMPL”). Specifically, the Regulations expanded the exceptions and safe harbors under the… Be Prepared: Submission of Breach Notifications Due to HHS by March 1, 2017
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… HHS OIG Publishes New Regulations that Expand its Authority to Exclude Health Care Providers from Participation in the Program
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… SAMHSA Final Rule on Confidentiality of Substance Use Disorder Patient Records
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… Preparing Your Facility for the MOON
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… CMS "Mid-Build" Exception Deadline and Provider-Based Growth Strategies
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… CoreMMIS Implementation Date
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,… New OCR and ONC Fact Sheet Discusses When PHI May be Disclosed for Health Oversight Activities
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… Implantable Cardiac Devices Raise Cyber-Security Concerns
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… |
© 2025 Krieg DeVault LLP. All Rights Reserved.
