On May 6, 2019, the US Department of Justice (“Department”) released “Guidance” describing certain steps that parties may take to earn “cooperation credit” in False Claims Act settlements. Cooperation credit refers to the government’s willingness to reduce damage multiples or “penalties” in actual FCA settlements. The Guidance will have direct […]
Health Law Alert
DHHS RFI on Reducing Regulatory Burdens
A new DHHS Request for Information on Reducing Administrative Burden to Put Patients Over Paperwork was published in the Federal Register on June 11, 2019. (84 FR 27070) The comment period is open for 60 days from the publishing date. As described in the notice, “[t]his RFI solicits additional public […]
Update on CMS Co-Location Guidance
CMS released draft guidance regarding requirements under the Conditions of Participation (“COPs”) for hospitals co-located with other hospitals and health care providers. The draft guidance was issued by the Director of the CMS Quality, Safety and Oversight Group on May 3, 2019, and is available here. CMS requested comments regarding […]
Update on CMS Claim Edits for Providers with Multiple Service Locations
CMS has pushed back the full implementation date for claim edits for providers with multiple service locations until October 2019. CMS has piloted claim edits that validate whether the service facility location on the claim form matches exactly the information submitted by the provider on its enrollment forms (CMS-855A) and […]
Iowa Passes Law Recognizing Lay Caregivers Following Inpatient Stay
On April 9, 2019, Governor Kim Reynolds signed into law Senate File 210 which provides for the designation of a lay caregiver following an inpatient stay at an Iowa hospital. The new law (referred to as the 2019 Iowa CARE Act) requires hospitals to implement discharge policies that require an […]

