The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently released an updated Special Advisory Bulletin1 covering the scope and effect of exclusion from Federal health care programs. The updated bulletin replaces and supersedes the OIG’s 1999 Special Advisory Bulletin on the effect of exclusion, and […]
Health Law Alert
New MSA Status For Nebraska Counties May Impact Stark Physician Relationships
The U.S. Office of Management and Budget recently announced new Metropolitan Statistical Areas (“MSAs”) based upon 2010 census data. In that announcement, a new MSA was created that includes Grand Island and the counties of Hall, Hamilton, Merrick and Howard. MSAs, by definition, have at least one urbanized area of […]
Federal Court Upholds OFCCP Jurisdiction Over Hospital
For years, we have been tracking the Department of Labor’s Office of Federal Contract Compliance Programs’ (“OFCCP”) efforts to expand its jurisdiction to health care employers. Generally, the OFCCP enforces regulations that require employers with at least 50 employees, who hold a single contract or subcontract of at least $50,000 […]
A Continued Challenge: The 3-Day Payment Rule Timeline
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 […]
OIG’s Update to the Provider Self-Disclosure Protocol Offers Expanded Detail and Transparency
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 […]

