On December 4, 2014, President Barack Obama signed into law (Pub. L. 113-198) which continued a de facto moratorium on enforcement of physician supervision requirements for critical access and small rural hospitals. Specifically, the law requires the Secretary of the Department of Health and Human Services to continue to instruct […]
Health Law Alert
PQRS Update – Payment Adjustments and Reporting Requirements
Many practitioners including physicians, physician assistants and nurse practitioners (“Eligible Professionals”) recently received a notice from the Centers for Medicare and Medicaid Services (“CMS”) stating that, in 2015, a negative reduction (-1.5%) in Medicare Physician Fee Schedule (“MPFS”) amounts would be imposed for failure to report under the Physician Quality […]
Evolving Trends in Enforcing Quality of Care Standards in Nursing Homes
Beds caked in feces and soaked in urine are not the typical living conditions for the nation’s nursing home population. These facts recently motivated Government officials to utilize ever evolving methods of enforcement to uphold quality of care standards for the elderly under Federal criminal statutes and the “worthless services” […]
ACOs and Tax-Exempt Financing
On October 24, 2014, the IRS released Notice 2014-67 which provides guidance for tax-exempt entities participating in ACOs as related to outstanding tax-exempt bonds. Particularly, the Notice provides (i) guidance relative to such an entity’s participation in an ACO; and (ii) a new private use safe harbor for management and […]
HRSA Withdraws 340B Program “Mega-Rule” in Favor of Informal Guidance
After a federal court ruled that the Health Resources and Services Administration (HRSA) did not have statutory authority to promulgate regulations on the 340B Drug-Pricing Program’s orphan drug exclusion, the agency has announced it will instead clarify key 340B policy issues through informal guidance. Prior to that ruling, HRSA planned […]