This month, the Health Resources and Services Administration (HRSA) issued additional 340B Program compliance audit results and its final rule on the orphan drug exclusion—clarifying several matters relevant to 340B covered entities amid continuing Program expansion and scrutiny by industry stakeholders. The federal 340B Drug-Pricing Program requires pharmaceutical manufacturers […]
Health Law Alert
Physician Licensure Discipline – Narcotics and Pain Management
on Wednesday, 31 July 2013 in
Health Law Alert: Erin E. Busch, Editor
Recent Nebraska disciplinary actions based on lax physician narcotic prescription practices suggest that it would be worthwhile for hospital and clinic medical staff to review their states’ published guidance on pain management practices. Not only do lax narcotic prescription practices place licensure at risk, but disciplinary action short of license […]
CMS Clarifies the Expanded Role of Telemedicine in Delivering CAH Emergency Services
on Friday, 28 June 2013 in
Health Law Alert: Erin E. Busch, Editor
Conditions of Participation On June 7, 2013, CMS released a helpful Memorandum1 clarifying the role that telemedicine can play in meeting CAH emergency room standards, both under conditions of participation and for EMTALA compliance. The Memorandum was triggered by widespread “misconceptions” on the part of critical access hospitals about whether […]
Community Health Needs Assessments – Proposed Rules Issued by the IRS
on Friday, 31 May 2013 in
Health Law Alert: Erin E. Busch, Editor
Tax-exempt hospitals are required by section 501(r) of the Internal Revenue Code to perform a community health needs assessment (“CHNA”) at least once every three years. Tax-exempt hospitals must both perform and complete a CHNA and formally adopt an implementation strategy based on the CHNA by the end of their […]
OCR Launches Nationwide Compliance Review of CAH Language Access Programs
on Friday, 31 May 2013 in
Health Law Alert: Erin E. Busch, Editor
On April 30th, the Office of Civil Rights (OCR) announced that it will begin compliance reviews to support language access programs in critical access hospitals (CAHs) as part of federal efforts to reduce health disparities. OCR reviews will focus on compliance with Title VI of the Civil Rights Act of […]
