Health Law Alert

Although the federal government recently postponed payment reviews for the new “two-midnight” rule, hospitals should prepare now for the approaching January 1, 2014 date, when reviews will resume. The two-midnight rule refers to an important clarification from the Centers for Medicare & Medicaid Services (CMS), in the FY 2014 IPPS […]

The Centers for Medicare and Medicaid Services (“CMS”) recently released eight frequently asked questions concerning the Self-Referral Disclosure Protocol (“SRDP”). The SRDP is a product of the Patient Protection and Affordable Care Act of 2010 and provides a process for providers and suppliers to self-disclose violations of the physician self-referral […]

The Office for Civil Rights recently published new guidance to assist law enforcement and covered entities when addressing information sharing situations where the HIPAA Privacy Rule may be at issue. The HIPAA Guide for Law Enforcement contains an overview of the Privacy Rule and describes permitted disclosures of health information […]

Click here to read the full September 2013 Health Law Advisory.  

In January 2013, the Office for Civil Rights published its lengthy final rule (often referred to as the “Omnibus Rule”) updating the HIPAA Privacy, Security, Breach Notification and Enforcement Rules. The updates were largely driven by HITECH. The Omnibus Rule changes were effective March 26, 2013, but OCR provided a […]