Health Law Alert

Tax-exempt hospitals are in various stages of compliance with the final 501(r) regulations. Calendar year taxpayers should have adopted and implemented compliant policies and procedures prior to the start of the new year. Fiscal year taxpayers have until the start of their 2016-17 tax year to adopt and implement compliant […]

Nearly five years after publishing the proposed rule, the Centers for Medicare & Medicaid Services (CMS) released a long-awaited final rule requiring documentation of face-to-face encounters to certify home health services for Medicaid beneficiaries. The final rule, published in the February 2, 2016 Federal Register, finalized the proposed rule originally […]

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 […]