Publications

In the May 23, 2017 decision in the case of Computer Support Services (d/b/a Cyzap) v. Vaccination Services (d/b/a TotalWellness), the Nebraska Court of Appeals considered whether a liquidated damages provision in a contract was enforceable.  In this case, an IT vendor called Cyzap had entered into an arrangement with […]

On July 13, 2017, CMS issued the 2018 Proposed Rules governing the outpatient prospective payment system and ambulatory surgery prospective payment system.  The Proposed Rules include a number of proposed policy changes which are subject to comment until September 11, 2017.  A final rule is expected to be published on […]

Whenever a hospital medical staff makes a decision that adversely affects a member’s privileges, it needs to determine whether to report the decision to the National Practitioner Data Bank (“NPDB”).  Those decisions can be surprisingly complex, as a recent Federal case highlights, and may depend on the wording of the […]

This is the second of a three-part overview of the new partnership audit rules codified in the Bipartisan Budget Act of 2015 (the “Act”) that will take effect January 1, 2018.  In Part 1, we provided an overview of the new partnership audit rules. In this Part, we describe the […]

In an effort to reflect a more “dynamic” work planning process, the OIG recently announced that, effective June 15, 2017, it went beyond its mid-year update by adding monthly updates to the annual Work Plan which are posted on the OIG’s website. See https://oig.hhs.gov/reports-and-publications/workplan/index.asp The OIG’s Work Plan is comprehensive […]