What do SEC football tickets and nail salon outings have in common? Both were “gifts” to physicians who referred business to a free standing imaging center in a recent settlement. Outside of health care, such gifts are often a regular part of rewarding clients for their business. But the federal […]
Health Law Alert
Update: CTA Filing Extended to January 13, 2025 for Entities Formed Prior to 2024
On the evening of December 23, 2024 the Department of Treasury announced that companies that were created or registered prior to January 1, 2024 and are not otherwise exempt under the Corporate Transparency Act (CTA) from filing a beneficial ownership information report (BOIR) with FINCEN now have until January 13, […]
Well, That was Quick – The Corporate Transparency Act is Back: Appellate Court Lifts Nationwide Injunction
On December 23, 2024, the Fifth Circuit Court of Appeals issued an order lifting the nationwide preliminary injunction that was previously issued by a federal district court in Texas on December 3, 2024 to suspend enforcement of reporting obligations for millions of businesses under the Corporate Transparency Act (CTA). Notably, […]
Cash in Lieu of Health Insurance Coverage for Employees Who Opt Out
A recent trend in the health care industry is employers offering additional (taxable) wages or other financial incentives in exchange for an employee declining coverage under the employer-sponsored group health plan. Regardless of the (often well-meaning) reason for offering these types of “cash in lieu” arrangements, employers must consider the […]
Extended Flexibilities—Prescribing Controlled Substances via Telemedicine
The U.S. Drug Enforcement Administration (DEA) and the U.S. Department of Health and Human Services (HHS) recently issued a regulation that extends the full set of telemedicine flexibilities regarding the prescribing of controlled medications that were implemented during the COVID-19 public health emergency (PHE). The flexibilities are now extended through […]

