Publications

On October 26, 2018, a new version of the National Practitioner Data Bank Guidebook was published by the Health Resources and Services Administration (HRSA), replacing the prior version published in April 2015. As background, hospitals and other health care entities are required to report adverse clinical privileges actions to the […]

Two recent developments from CMS related to provider-based departments: Payment Rates for Off-Campus Provider-Based Hospital Departments Paid Under the PFS Section 603 of the Bipartisan Budget Act of 2015 changed the reimbursement source for certain items and services furnished by some off-campus hospital outpatient provider-based departments. The change was to […]

In November 2018, CMS issued its final rule for the Medicare Physician Fee Schedule. In a previous article, we had summarized the changes to E&M coding that CMS had proposed in its July 27, 2018 proposed rule. In this final rule, CMS delayed until 2021 any changes to reimbursement for […]

In November 2018, Senator Ron Wyden (D-OR) released a discussion draft of the Consumer Data Protection Act (the “Act”), which would empower the Federal Trade Commission (the “FTC”) to regulate data privacy practices, sanction companies and their senior executives for improper practices regarding personal information, and provide consumers with better […]

In the months since the General Data Protection Regulation (“GDPR”) went into effect on May 25, 2018, data protection authorities (“DPAs”) have received thousands of complaints from European Union (“EU”) residents. The European Data Protection Board, an independent data protection authority based in the EU, reported that more that 42,000 […]