Publications

On September 27, 2018, a new post on the OIG website www.oig.hhs.gov educates providers about the Fraud “Risk Spectrum” which categorizes risk from low to the high as follows: the highest risk is program exclusion, followed by the high risk of heightened scrutiny, the medium risk of imposition of a […]

Section 501(r) of the Internal Revenue Code (“Code”) and the final regulations published by the IRS put into place very specific requirements for tax-exempt hospitals relative to financial assistance policies (FAPs) and community health needs assessments (CHNAs). The Code requires the IRS to perform desk reviews of the Form 990, […]

On September 20, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that would “reform Medicare regulations that are identified as unnecessary, obsolete, or excessively burdensome on health care providers and suppliers” (“Proposed Rule”). One of the more significant proposals would eliminate the current comprehensive medical […]

Recently, Alabama 1 and South Dakota 2 joined the other 48 States by enacting data breach legislation that requires entities (private or public) to notify individuals of security breaches of information involving personally identifiable information. While the South Dakota’s law followed the majority of its predecessors, the Alabama law imposes […]

Since the 2016 election, insiders for the financial services industry have predicted that the Trump Administration would bring not just a roll-back in federal regulation, but a different, more relaxed approach to enforcement as well. At the same time, others have predicted that any roll-back in federal oversight on the […]