On October 31, 2014, the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) released its Work Plan for fiscal year 2015. The Work Plan identifies key areas of review and activities that the OIG plans to pursue in the upcoming year, in an effort to […]
Health Law Alert
Electronic Health Records: The Cut and Paste Debate
Two years ago, in September, 2012, the U.S. Attorney General and the Secretary of Health and Human Services issued a joint letter seeking cooperation from the America Hospital Association and other health care associations, to ensure that electronic health records (EHR) were not used to inflate claims to the Medicare […]
Fix Up the Hospital Van: OIG Proposes Transportation Safe Harbor; Clarification on ACA CMP Exception
On October 3, 2014, the Office of Inspector General of the Department of Health and Human Services (“OIG”) released a proposed rule expanding safe harbors under the anti-kickback statute and clarifying the exceptions to “remuneration” under the Civil Monetary Penalties (“CMP”)/beneficiary inducement laws. The proposed rules respond to longstanding concerns […]
OSHA Revises Record-Keeping Requirements
The Occupational Safety and Health Administration recently announced revised record-keeping requirements that will go into effect on January 1, 2015, for workplaces under OSHA’s jurisdiction. Under the revised rule, employers will be required to notify OSHA of work-related fatalities within eight hours, and work-related in-patient hospitalizations, amputations or losses of […]
Sign of the Times? IRS Complaint from Non-Profits Alleges Florida Health System Failed to Follow 501(r) Requirements
Two non-profits serving low-income families in Florida are attempting to hold one of the state’s largest providers of charity care accountable to the requirements for tax-exempt hospitals adopted under the Patient Protection and Affordable Care Act (ACA). Florida Legal Services, Inc. (FLS) and the National Health Law Program (NHeLP) filed […]

