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Students, Consultants and Other Business Visitors...Important Safeguards

By: Susan E. Ziel and Robert A. Anderson on May 1, 2019

If you are a health care clinic or other office setting, do you have a policy that governs those individuals or “business invitees” who may request and be granted the opportunity to observe or participate in some aspect of your business or clinical…

Recent HOPD Address Issues

By: Thomas N. Hutchinson and Meghan M. Linvill McNab on May 1, 2019

Beginning in April 2019, CMS started returning OPPS claims where the Hospital Outpatient Department address on the claim does not match the exact address appearing on the hospital’s Medicare Form 855A.

These include claims returned for using “Ste.”…

Investigatory Records Exception to Indiana's Access to Public Records Act ("APRA") Analyzed by Court of Appeals

By: Christopher W. Bloomer and Robert S. Schein on April 30, 2019

Few statutes contain a clearer enumerated purpose than Indiana’s Access to Public Records Act or “APRA.” Passed originally in 1983, the Legislature found that providing persons with information is an essential function of representative government,…

Is Your Organization in Compliance With IRS Rules on Employer Identification Numbers?

By: Kendall A. Schnurpel on April 29, 2019

On March 27, 2019 the IRS announced that taxpayers can no longer request an employer identification number (“EIN”) unless the “responsible party” named on the application has a Social Security number (“SSN”) or Individual Taxpayer Identification…

Is Your Organization in Compliance With IRS Rules on Employer Identification Numbers?

By: Kendall A. Schnurpel on April 29, 2019

On March 27, 2019 the IRS announced that taxpayers can no longer request an employer identification number (“EIN”) unless the “responsible party” named on the application has a Social Security number (“SSN”) or Individual Taxpayer Identification…

Is Your Organization in Compliance With IRS Rules on Employer Identification Numbers?

By: Kendall A. Schnurpel on April 29, 2019

On March 27, 2019 the IRS announced that taxpayers can no longer request an employer identification number (“EIN”) unless the “responsible party” named on the application has a Social Security number (“SSN”) or Individual Taxpayer Identification…

Is Your Organization in Compliance With IRS Rules on Employer Identification Numbers?

By: Kendall A. Schnurpel on April 29, 2019

On March 27, 2019 the IRS announced that taxpayers can no longer request an employer identification number (“EIN”) unless the “responsible party” named on the application has a Social Security number (“SSN”) or Individual Taxpayer Identification…

Medical Record Documentation: Is it a “No” or a “Not Completed”?

By: Robert A. Anderson and Meghan M. Linvill McNab on April 9, 2019

The United States Department of Justice (“DOJ”) issued a press release regarding a recent $2 Million settlement related to allegations that a provider violated the False Claims Act by submitting inflated and upcoded evaluation and management (“E/M”)…

New Medicare Payment Model for Emergency Ambulance Services

By: Meghan M. Linvill McNab and Amanda K. Schipp on April 9, 2019

On February 14, 2019, the Center for Medicare and Medicaid Innovation (“CMMI”) announced a new payment model for Medicare emergency ambulance services called the “Emergency Triage, Treat and Transport (“ET3”) Model.  The goal of the ET3 Model is to…

OCR Concludes Investigation of Allegations that the State of Hawaii Unlawfully Discriminated Against Pregnancy Resource Centers

By: Robert A. Anderson and on April 8, 2019

On March 21, 2019, the Office for Civil Rights (“OCR”) at the U.S. Department of Health and Human Services (“HHS”) issued a resolution to resolve complaints brought against the State of Hawaii by two pregnancy resource centers (the “Centers”). The…

D.C. District Court Invalidates Medicaid Work Requirements

By: and Brandon W. Shirley on April 8, 2019

D.C. District Court Judge James Boasberg invalidated Federally approved Medicaid work requirements in Kentucky and Arkansas and sent the question back to the Centers for Medicare and Medicaid Services (“CMS”) for further analysis. The March 27, 2019…

HIPAA, Individual Rights and Personal Representatives

By: Susan E. Ziel and on April 8, 2019

The Health Insurance Portability and Accountability Act of 1996, as amended by the Health Information Technology for Economic and Clinical Health or “HITECH” Act  (hereinafter “HIPAA”)1 establishes numerous obligations for HIPAA covered entities and…

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