Health Law Alert

In early February, the Centers for Medicare & Medicaid Services (CMS) issued regulations implementing the Physician Payments Sunshine Act, one of several Affordable Care Act mandates intended to create additional transparency in the health care market.    The Sunshine Act requires manufacturers of drugs, devices, biological, and medical supplies covered […]

Over the past few months, we have received a number of calls from representatives of governmental hospitals inquiring about the application of section 501(r) of the Internal Revenue Code to their respective organizations.  Some governmental hospitals have assumed that, because they are not obligated to file a Form 990, 501(r) […]

The decision to enter into an arrangement to have another organization host your data will be driven by a number of factors such as: resource availability, technical considerations, location diversity, and cost.  One of the factors which must be considered is the HIPAA Security Rule.   If the hosting arrangement […]

Hospitals and health care organizations are more frequently hosting data or back-up data at off-site data locations.  While segregating data by hosting data off site is generally an advisable risk management strategy, hospitals have also entered arrangements to host data for third parties (including other hospitals).  This practice may leave […]

As we near the ten year anniversary of covered entities complying with the original HIPAA Privacy Rule (April 14, 2003), the Office for Civil Rights (OCR) has issued a wake-up call with the publication of a consolidated final rule implementing new and enhanced standards for Privacy, Security, Enforcement and Breach […]