Health Law Alert

Appendix Q to the State Operations Manual sets out surveyor guidance regarding Immediate Jeopardy findings. The revised guidance published by CMS in a Quality, Safety and Oversight Memo on March 5, 2019, includes a “Core” Appendix Q applicable to all provider and supplier types. Two subparts, applicable to nursing homes […]

On February 8, 2019, the Iowa Supreme Court, in Colwell v. Iowa Department of Human Services1 , limited dentists’ billing rights under Iowa Medicaid (“Medicaid”) by concluding that dentists cannot charge Medicaid patients when the managed care organization (“MCO”) denies reimbursement for covered services. In 2014, Iowa’s Medicaid expansion program […]

On February 1, 2019, the EEOC announced its extension of the EEO-1 filing deadline to May 31, 2019. The EEO-1 survey must be filed annually by private employers with 100 or more employees, and by federal contractors with 50 or more employees and a federal contract/subcontract in excess of $50,000. […]

The Healthcare Information and Management Systems Society (“HIMSS”) conference took place earlier this month. During his session at the conference, OCR Director Roger Severino announced a new enforcement initiative emphasizing compliance with patients’ rights of access to their health information. When asked to comment on this announcement, an HHS spokesperson […]

The Eliminating Kickbacks in Recovery Act of 2018, to be codified at 18 U.S.C. § 220 (“EKRA”), expands criminal liability for any remuneration or kickback paid for referrals to laboratories, recovery homes and detoxification and substance use treatment facilities. EKRA provides for criminal sanctions including a fine in the maximum […]