CMS recently promulgated a few updates to the Stark rules in the 2022 Medicare Physician Fee Schedule (PFS) Final Rule. Highlights of the changes are as follows: Indirect Compensation Arrangements Prior to 2021, “indirect compensation arrangements” only arose if an unbroken chain of financial relationships existed between a physician and […]
Health Law Alert
Federal Trade Commission Returns to its Throne
on Tuesday, 23 November 2021 in
Health Law Alert: Andrew D. Kloeckner, Editor
On July 21, 2021, the Federal Trade Commission rescinded a longstanding 1995 Policy Statement that limited the Commission’s ability to deter anticompetitive or problematic mergers and acquisitions. Prior to the 1995 Policy Statement, the Commission required a company that allegedly or actually violated the law in a previous merger or […]
Surprise – No Surprises Act – Part II Interim Final Rule
on Monday, 25 October 2021 in
Health Law Alert: Andrew D. Kloeckner, Editor
On September 30, 2021, the Department of Health and Human Services, the Department of Labor, the Department of Treasury, and the Office of Personnel Management released an interim final rule, “Requirements Related to Surprise Billing: Part II” (hereinafter referred to as the “Rule.”). The Biden administration describes the Rule as […]
Mandating the COVID-19 Vaccine: Considerations for Health Care Employers
on Tuesday, 7 September 2021 in
Health Law Alert: Andrew D. Kloeckner, Editor
Health care employers across the United States that have not yet mandated the COVID-19 vaccine for their employees are currently considering it. Undoubtedly, whether to mandate vaccinations is now one of the most pressing employment law issues facing the health care industry. Some health care employers have the “luxury” of […]
Does Telemedicine Provide Necessary Physician Supervision for PAs? Not Unless Your Contract Says So.
on Tuesday, 7 September 2021 in
Health Law Alert: Andrew D. Kloeckner, Editor
These days, both nurse practitioners and physician assistants practice regularly in hospital emergency departments. In many critical access hospitals they cover primary call for the ED, with a supervising physician taking secondary call. With increased reliance upon contracted telemedicine to cover the ED in a back-up fashion, questions have arisen […]