On December 7, 2016, the Office of Inspector General (OIG) of the Department of Health and Human Services updated the threshold for gifts of “nominal value” for Medicare beneficiaries from $10 to $15 per item and $50 to $75 in total for a patient on an annual basis. The Civil […]
Health Law Alert
Congress Extends Moratorium on Enforcement of Supervision Requirements for CAHs (Again)
on Friday, 13 January 2017 in
Health Law Alert: Kristin N. Lindgren, Editor
It’s déjà vu all over again. For the third time in as many years, Congress passed an enforcement moratorium on physician supervision requirements for critical access and small rural hospitals. Section 16004 of the 21st Century Cures Act—signed by outgoing President Barack Obama on December 13, 2016—extends the Centers for […]
HIPAA Breach Log: 2016 Breach Reports Due March 1, 2017
on Friday, 6 January 2017 in
Health Law Alert: Kristin N. Lindgren, Editor
With the end of 2016, covered entities must remember to file all breach reports with OCR. If a covered entity experienced a breach (as defined in the data breach notification rule) during 2016, the deadline for reporting the breach to OCR is March 1, 2017. Covered entities have 60 days […]
CMS Final Rule Implementing the NOTICE Act and its Effect on Hospitals and Critical Access Hospitals
on Sunday, 25 December 2016 in
Health Law Alert: Kristin N. Lindgren, Editor
The Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act) requires hospitals and critical access hospitals (CAHs) to provide written and oral notification and explanation of observation services to outpatients receiving observation services for more than 24 hours at a hospital or CAH. On August 22, 2016, […]
Telemedicine and EMTALA Compliance by CAHs
on Thursday, 15 December 2016 in
Health Law Alert: Kristin N. Lindgren, Editor
As large hospitals and health systems reach out to critical access hospitals (“CAHs”) offering emergency medicine expertise by telemedicine, the question arises as to how the CAH can use that service while still meeting its legal obligations under the Emergency Medical Treatment and Active Labor Act (“EMTALA”). The Centers for […]
