Health Law Alert

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 […]

On October 26, 2018, a new version of the National Practitioner Data Bank Guidebook was published by the Health Resources and Services Administration (HRSA), replacing the prior version published in April 2015. As background, hospitals and other health care entities are required to report adverse clinical privileges actions to the […]

Two recent developments from CMS related to provider-based departments: Payment Rates for Off-Campus Provider-Based Hospital Departments Paid Under the PFS Section 603 of the Bipartisan Budget Act of 2015 changed the reimbursement source for certain items and services furnished by some off-campus hospital outpatient provider-based departments. The change was to […]