On August 26, 2019, HHS’s Substance Abuse and Mental Health Services Administration (“SAMHSA”) published a Proposed Rule updating the regulations on the Confidentiality of Substance Use Disorder Records (“Part 2”). Part 2 Programs, which can be stand-alone facilities or individuals or departments of general medical facilities whose primary function is […]
Health Law Alert
The Evolution of Price Transparency Requirements for Hospitals in the FY 2020 Medicare Proposed Outpatient Prospective Payment Rule
The Centers for Medicare and Medicaid Services (“CMS”) issued a controversial proposed rule regarding price transparency for hospitals as part of the FY 2020 Outpatient Prospective Payment Proposed Rule. In its fact sheet regarding these provisions of the proposed rule, CMS noted that President Trump signed an Executive Order on […]
Nebraska Attorney General Publishes Sexual Assault-Related Injury Reporting Protocol
Last year, the Nebraska Unicameral updated Nebraska’s Wounds of Violence reporting statute. In the statutory update, the Attorney General was directed to develop and distribute a statewide model protocol for the submission of anonymous reports of actual or attempted sexual assaults by July 2019. In the interim, the Attorney General’s […]
Recent OIG Settlement is a Reminder that Stark Applies to Physician Compensation Practices in Private Physician Groups
On August 15, 2019, the OIG announced a $1.2 million settlement with a private Alabama orthopedic group. One of the allegations was that the Group had violated the Stark laws because the Group paid its shareholder physicians directly or indirectly based on the volume of each shareholder physician’s referrals for […]
Senator Grassley Requests Update on 501(r) Compliance Efforts
Section 501(r) of the Code established a number of requirements for tax-exempt hospitals, including provisions related to financial assistance policies, limitations on charges, and billing and collection matters. Every § 501(c)(3) tax-exempt hospital, including “dual status” governmental hospitals (those governmental hospitals that separately obtained § 501(c)(3) status), must adopt and […]