Publications

On September 17, 2019, US District Judge Rosemary Collyer of the District of Columbia struck down CMS’ policy included in the CY2019 Outpatient Prospective Payment System (OPPS) rule that cut Medicare payment rates to hospitals offering physician services. The policy established payment for medical services provided in off-campus, hospital outpatient […]

Earlier this year, the U.S. Department of Health and Human Services, Office for Civil Rights (OCR) announced that it would vigorously enforce the rights of patients to receive copies of their medical records in a timely fashion. OCR held true to its word, and, on September 9, 2019, announced the […]

In the first half of 2019, the Federal Trade Commission (“FTC”) entered into settlement agreements with several entities whose data security programs were inadequate or non-existent. Unlike previous settlements, these recent settlement agreements impose specific security requirements rather than “reasonable security safeguards.” The FTC’s most recent settlement agreement with LightYear […]

New Hampshire signed into law Senate Bill 194-FN, the Insurance Data Security Law, on August 2, 2019, which requires insurers licensed in New Hampshire to implement an information security program, investigate cybersecurity events, and report such cybersecurity events to the New Hampshire insurance commissioner. This law is effective January 1, […]

While businesses prepare to comply with the California Consumer Privacy Act (“CCPA”), Nevada quietly passed an amendment to its online privacy law that requires businesses to offer consumers a right to opt-out of the sale of their personal information. The amended law will be effective October 1, 2019 – three […]