Health Law Alert

As of January 1, 2019, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) may seek reimbursement for certain communication technology-based services, including short medical discussions and remote evaluations of recorded audio and/or video. In the preamble to the 2019 Physician Fee Schedule Final Rule, CMS recognized that allowing […]

As we close the books on 2018, covered entities must remember to file all small breach reports with OCR. For small breaches (those impacting less than 500 individuals), covered entities have 60 days following the end of the year in which the breach occurred to report any breach for the […]

For those of you who attended the Baird Holm Health Law Forum in November 2018, you may remember reference to an unusual provision in the Tax Cuts and Jobs Act that makes tax–exempt employers liable for unrelated business income tax on the cost of the parking provided to employees. It’s […]

The U.S. Department of Justice (“DOJ”) recently issued revisions to its Justice Manual that soften the impact of the September 2015 “Yates Memo,” named after its author, then-Deputy Attorney General Sally Yates. The Yates Memo instructed federal prosecutors not to give a corporate defendant any credit for cooperation unless the […]

On December 14, 2018, OCR issued a Request for Information (“RFI”) asking how HIPAA can be revised to better promote care coordination and value-based care while preserving privacy and security protections. The RFI is relatively short, and easily digestible. It categorizes its requests into four topic areas, asking more specific […]