The Department of Justice (” DOJ”) recently published a report on its public website called “Evaluation of Corporate Compliance Programs.” The intention of the guidance is to provide transparency about the factors that the DOJ will consider in reviewing information from organizations involved in DOJ investigations. Organizations involved in self-disclosures […]
Health Law Alert
MOON Notices Have Been Required Since March 8, 2017
on Tuesday, 7 March 2017 in
Health Law Alert: Kristin N. Lindgren, Editor
On March 8, 2017, Medicare hospitals and critical access hospitals (“CAH”) were required to begin giving notices to Medicare patients who remain in observation bed status for more than 24 hours. The Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act) was adopted in August 2015, establishing the Medicare […]
Federal District Court Issues Nationwide Preliminary Injunction on OCR’s Interpretation of “Sex” Under Section 1557
on Tuesday, 21 February 2017 in
Health Law Alert: Kristin N. Lindgren, Editor
On December 31, 2016, U.S. District Court Judge Reed O’Connor granted the plaintiff’s motion for preliminary injunction in their challenge to the definition of “sex” under the Office for Civil Rights (OCR) Section 1557 final regulations. The practical effect of Judge O’Connor’s ruling is that any current steps that covered […]
Fix Up the Hospital Van (Again!): OIG Finalizes Local Transportation Safe Harbor
on Tuesday, 14 February 2017 in
Health Law Alert: Kristin N. Lindgren, Editor
In early December 2016, the Department of Health and Human Services Office of Inspector General (OIG) finalized the local transportation safe harbor under the Federal anti-kickback statute (81 FR 88368). Health care providers of all types have long offered transportation to patients in need with the primary motivation being increased […]
Sixty Days Means … Sixty Days: Recent OCR Action Highlights the Need for Timely Breach Notification
on Tuesday, 7 February 2017 in
Health Law Alert: Kristin N. Lindgren, Editor
The U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) recently announced a settlement based on a covered entity’s failure to meet the breach notification timeline requirements set forth in the Health Insurance Portability and Accountability Act of 1996 Breach Notification Rule (Rule). On January 9, […]
