The federal Health Care Quality Improvement Act (“HCQIA”) directs creation of what has come to be known as the National Practitioner Data Bank (“NPDB”) and mandates reporting by healthcare entities in two scenarios. The first scenario is when a healthcare entity takes adverse professional review action against a physician’s or […]
Health Law Advisory
The federal No Surprises Act (the “Act”) will go into effect on January 1, 2022. Regulations are expected in July, October and December, 2021. The Act is complicated on its own, but it is designed to recognize and dovetail with pre-existing state No Surprises Acts in a couple of situations. […]
CDC Updates COVID-19 Vaccination Program Provider Agreement to Address Use and Disclosure of Vaccination Data
On May 18, 2021, the Centers for Disease Control (CDC) posted an amendment to the Vaccination Program Provider Agreement to provide additional restrictions on what providers participating in the federal vaccination program can do with personal data gathered on vaccine recipients. The amendment, which is automatically imposed on all vaccine […]
CMS has imposed additional COVID-19-related education, vaccination, documentation and reporting requirements on Medicare SNFs and Medicaid Nursing Homes (collectively “LTCs”). The action comes in the form of an interim final rule with comment period published May 13, 2021, and effective May 21, 2021. The new rule also imposes parallel requirements […]
The Office for Civil Rights (“OCR”) proposed changes to the HIPAA Privacy Rule last winter. While comments were originally due in March, OCR extended the timeline until May 6, 2021. To comment before the deadline, you should use the comment portal available on federalregister.gov.