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” […]
Health Law Alert
ACOs and Tax-Exempt Financing
on Friday, 19 December 2014 in
Health Law Alert: Kristin N. Lindgren, Editor
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
on Monday, 15 December 2014 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
Highlights of the OIG 2015 Work Plan
on Monday, 8 December 2014 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
Electronic Health Records: The Cut and Paste Debate
on Friday, 21 November 2014 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
