Click here to read the full September 2013 Health Law Advisory.
Health Law Alert
Reminder: The HIPAA “Omnibus Rule” is Now in Effect
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 […]
Reminder of New DME Face-to-Face Requirements
The Centers for Medicare and Medicaid Services (“CMS”) recently announced that enforcement of the face-to-face requirement for providers ordering durable medical equipment (“DME”) will be postponed until 2014. While implementation of the rules has been delayed, providers and suppliers should be familiar with the requirements. The following set of questions […]
CMS Provides Guidance on Enrollment and Certification During Mergers and Acquisitions
On September 6, 2013, CMS issued a survey and certification letter to state survey agency directors that provides guidance on the automatic assignment of Medicare provider agreements in health care transactions including mergers and acquisitions. Providers and suppliers who engage in these transactions should be familiar with the guidance, as […]
HIPAA Threat of Harm Exception Gets a Second Look
Prompted by the tragic shootings in Newtown, Connecticut, and Aurora, Colorado, the HHS Office for Civil Rights (OCR) released a letter to all health care providers on January 15, 2013 making them “aware” that the HIPAA Privacy Rule does not prevent their “ability to disclose necessary information about a patient […]