Health Law Alert

On February 12, 2016, nearly four years after publishing a proposed rule, the Centers for Medicare and Medicaid Services (CMS) released a final rule implementing Section 6402(a) of the Affordable Care Act (the “Final Rule”) which provides for a 60-day timeline for reporting and returning overpayments. The Final Rule requires […]

HIPAA Individuals’ Right to Access to Records. DHHS recently posted a lengthy document providing very detailed guidance on the individual’s right under HIPAA to access their health information (45 CFR §164.524). www.hhs.gov/hipaa/for-professional/privacy/ guidance /access. The OIG website http://oig.hhs.gov features monthly update podcasts. The January 2016 podcast discussed recent enforcement actions […]

On January 6, 2016, the Department of Health and Human Services issued a Final Rule modifying the HIPAA Privacy Rule. The new Rule expressly permits the disclosure of PHI to the National Instant Criminal Background Check System (NICS) for certain covered entities. The Rule aims to strengthen the accuracy of […]

Vintage clothes, vintage wine and vintage cars are all great, but not vintage compliance policies. So what has changed that makes it vital for compliance policies and activities to be updated now? Updates to Compliance Guidance. The original compliance program guidance document was published in 1998 for hospitals, followed closely […]

In November, the Office of Inspector General (OIG) issued its fiscal year 2016 Work Plan giving the industry insight as to the new and ongoing priorities of the OIG. The Work Plan summarizes the prior year’s results, which reflect the OIG’s progression toward an increasing focus on civil actions between […]