Health Law Alert

The Centers for Medicare and Medicaid Services’ 3-day and 1-day payment rules (the “Payment Rules”) continue to generate many questions among health care providers and suppliers concerning effective dates, changes, and application of the Payment Rules. Under the Payment Rules, a hospital (or an entity that is wholly owned or […]

The updated Provider Self- Disclosure Protocol (SDP) issued April 17, 2013 by the OIG expanded and updated the original SDP issued on October 30, 1998 and the OIG’s Open Letters to health care providers issued subsequent to the original SDP. Both the original and the updated SDP provide guidance on […]

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 […]