Last month, we updated you on the proposed Washington Privacy Act (SB 5376) and the fact that the law, if passed, would mirror the European Union’s General Data Protection Regulation (“GDPR”). Despite passing the Washington Senate almost unanimously and being supported by the technology industry, the bill hit a roadblock […]
Publications
Highlights from the IAPP Global Privacy Summit: OCR and HIPAA
This May, Timothy Noonan (“Noonan”), acting deputy director for health information privacy at the Office for Civil Rights (“OCR”), sat for a Q&A session at the International Association of Privacy Professional’s (“IAPP”) annual Global Privacy Summit in Washington, DC. Noonan discussed a variety of topics, including OCR’s HIPAA enforcement priorities, […]
IRS Expands Determination Letter Program
In a May 1, 2019, Revenue Procedure, the IRS expanded the determination letter program to reach statutory hybrid plans and plan mergers. As background, in 2017, the IRS significantly narrowed the application of its determination letter program for individually designed qualified plans. Prior to 2017, individually designed retirement plans were […]
EEO-1 Pay Data Roller Coaster
In a whirlwind few weeks, the fate of the EEO-1 Pay Data requirement (referred to as “Component 2”) was finally decided…or was it? As a quick refresher, the EEO-1 survey must be filed annually by private employers with 100 or more employees, and by federal contractors with 50 or more […]
Permanent Relief or the New SGR? Proposed Legislation Would Permanently Extend Enforcement Instruction For Outpatient Therapeutic Services in Cahs
In late March, South Dakota Republican Senator John Thune introduced S. 895 that would permanently extend the Centers for Medicare & Medicaid Services’ enforcement instruction to its contractors that Critical Access Hospitals do not need to provide direct supervision for outpatient therapeutic services furnished in its facilities. In general, CMS […]

