With the recent implementation of the final 501(r) regulations, many tax-exempt hospitals have significantly revised their charity care and billing and collection policies and practices. However, one issue that may have flown under the radar for many is the delay or denial of care due to the non-payment of outstanding […]
Health Law Alert
Updates to OIG’s Permissive Exclusion Authority
The Department of Health and Human Services Office of Inspector General (OIG) published updated criteria to its permissive exclusion authority under § 1128(b)(7) of the Social Security Act (the Act) (42 USC § 1320a-7(b)(7)). The guidance—published in mid-April and available here—introduced an OIG “risk spectrum” and several factors the Agency […]
Iowa Included in DOJ’s Multi-Agency Effort Targeting Elder Abuse
In late March 2016, the Department of Justice (DOJ or the Department) announced several Elder Justice Task Forces throughout the United States to combat elder abuse in nursing facilities and other facilities providing services to the elderly. The Northern District of Iowa was selected as one of the DOJ’s ten […]
Nebraska Adopts Surgical First Assistant Practice Act
Nebraska has joined a number of states in adopting an additional licensure category for surgical first assistants. The Act, which becomes effective January 1, 2017, states “surgical first assistants aid in ensuring a safe surgical environment by maximizing patient safety by using appropriate techniques for processes including, but not limited […]
CMS 2-Midnight Policy Unchanged; But Related IPPS Reductions Reversed By FY2017 Increase
The Policy Itself: The 2-Midnight Policy was adopted by CMS effective for admissions on or after October 1, 2013. The rule provided that an inpatient admission is appropriate for Medicare Part A payment if the physician (or other qualified practitioner) admits the patient as an inpatient based on the reasonable […]

