The Nebraska Legislature has twelve legislative days left in the 2017 session. This week, the Legislature will finalize the biennial budget in an effort to close the projected $900 million shortfall. Also, the Legislature may again take up a measure to fund property tax, and potentially, income tax, relief (AM […]
Publications
Compliance 2.0
DHHS Inspector General Daniel R. Levinson’s keynote address at the 2017 Health Care Compliance Association (“HCCA”) Compliance Institute in late April focused on the future of compliance, targeting several key themes: This is Compliance 2.0. IG Levinson noted that the compliance industry is about 20 years old and we are […]
Free or Discounted Local Transportation Permitted under New Safe Harbor
A new safe harbor under the Anti-Kickback Statute (“AKS”) permits providers to offer free or discounted transportation services to patients. The safe harbor permits both direct transportation offered to individuals, and shuttle services that follow a regular route, subject to a number of conditions. The conditions for the safe harbor […]
Recent Amendments to SEC Rule 504 “Seed Capital” Exemption and Securities Act of Nebraska Exemption
Since its original adoption in 1982, Securities and Exchange Commission (“SEC”) Regulation D, Rule 504 has been limited in amount to the issuance of no more than $1 million in securities in a 12-month period. Effective January 20, 2017, the SEC increased the maximum offering amount to $5 million in […]
CMS Issues New Stark Self Disclosure Form
Prior to the enactment of the Patient Protection and Affordable Care Act (the “Act”), CMS had no express authority to negotiate settlements of, and reduce the liabilities associated with, Stark violations. Providers had two alternatives: (i) the provider could repay the entire amount paid by Medicare as a result of […]