Health Law Alert

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 […]

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) […]