Health Law Alert

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 […]

A fairly new addition to the OIG’s website www.oig.hhs.gov is the Compliance Resource Portal which is accessed by selecting “Compliance” on the homepage and clicking the link to “Visit the Compliance Resource Portal.” The Compliance Resource Portal includes long-standing pages such as Fraud Alerts, Guidance and Safe Harbor Regulations, Resources […]

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 […]