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 […]
Health Law Alert
Mandating the COVID-19 Vaccine: Considerations for Health Care Employers
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.
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 […]
CMS Proposes, and Then Backs Away, from Increased Penalties to Address Non-Compliance with the Price Transparency Rule
In the proposed 2022 Outpatient Prospective Payment System (“OPPS”) rule released on July 19th, the Centers for Medicare and Medicaid Services (“CMS”) proposed increasing penalties for hospitals not in compliance with the price transparency requirements that took effect for hospitals on January 1, 2021. A portion of the price transparency […]
President Biden Issues Executive Order Addressing Competition in Health Care
On July 9, 2021, President Biden issued the “Executive Order on Promoting Competition in the American Economy,” which set out a “whole-government policy” of enforcing antitrust laws to prevent excessive consolidation and thus improve competition. Encompassing a wide range of directives and policy statements, the order specifically targets four important […]

