A variety of situations raise the question of whether or not a hospital or other licensed health care facility has an obligation to report an individual licensee’s improper behavior, act or omission to the licensee’s state board. Often, it is assumed that what may be a reportable event by an […]
Health Law Alert
Under the Travel Act, Private-Pay Kickbacks Can Be Federal Crimes
Preventing financial misconduct in the health care industry has long been a major focus of federal law enforcement. The Trump administration recently affirmed its commitment to maintaining that priority. A September federal court decision indicates that the Department of Justice may even be expanding its prosecutions to reach health care […]
Leased Outreach Clinic Arrangements Disfavored by CMS
After the well-publicized CMS enforcement action against St. Peter’s Hospital in Helena, Montana, in October, 2015, there was substantial confusion within the hospital industry about the effect of leasing licensed hospital space to private physicians for the purpose of periodic outreach clinics. In the case of St. Peter’s, the hospital […]
CMS Announces Delay in Effective Date for New Home Health Agency Conditions of Participation; Congress Questions Impact of Proposed Home Health Agency Reimbursement Changes
Home health agencies (“HHAs”) are struggling to deal with changes from the Centers for Medicare and Medicaid Services (“CMS”) on two fronts. On July 10, 2017, CMS released a final rule delaying the effective date of the changes to the Conditions of Participation (“COPs”) for HHAs that was published on […]
Written Physician Assistant Supervisory Agreements Are Now Required in Iowa
On September 15, 2017, the Iowa Board of Medicine published final administrative regulations governing the supervision of physician assistants PAs in Iowa. Although the new rules are effective September 20, 2017, enforcement of the rule is delayed until January 1, 2018 in order to allow time for education and implementation. […]