Health Law Alert

While the volume of Resolution Agreements coming out of OCR in 2018 have been significantly less than in prior years (five thus far in 2018 versus 10 for the same period in 2017), with each Resolution Agreement, OCR continues to send very strong messages to covered entities and there are […]

On September 28, 2018, the Iowa Department of Human Services issued an informational letter (Informational Letter No. 1953-MC-FFS-D) to all Federally Qualified Health Centers (“FQHCs”) that eliminated the productivity requirements that had previously applied to FQHCs in Iowa. The change is effective for cost reporting periods ending on or after […]

On October 24, 2018, CMS released “inaugural” QRP data on Nursing Home Compare regarding skilled nursing facilities (SNFs). This release is in accordance with Section 1899B(g)(1) of the Social Security Act requiring CMS to publicly report SNF provider performance on selected quality measures. Reporting of certain quality measures is also […]

On September 27, 2018, a new post on the OIG website www.oig.hhs.gov educates providers about the Fraud “Risk Spectrum” which categorizes risk from low to the high as follows: the highest risk is program exclusion, followed by the high risk of heightened scrutiny, the medium risk of imposition of a […]

Section 501(r) of the Internal Revenue Code (“Code”) and the final regulations published by the IRS put into place very specific requirements for tax-exempt hospitals relative to financial assistance policies (FAPs) and community health needs assessments (CHNAs). The Code requires the IRS to perform desk reviews of the Form 990, […]