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 […]
Health Law Alert
New Law Expands Kickback Liability Beyond Public Health Care Programs
on Tuesday, 5 February 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
Have You Seen the Compliance Resource Portal?
on Tuesday, 5 February 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
Rural Health Clinics and Federally Qualified Health Centers Can Bill for Certain Virtual Communication Services
on Tuesday, 5 February 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
Reminder: 2018 Small Breach Reports Due March 1, 2019
on Tuesday, 5 February 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
