In two recent memoranda issued by the United States Department of Justice (“DOJ”), the agency signaled an approach favorable to hospitals and other providers. The DOJ stated in one memorandum that reliance on agency guidance documents in affirmative civil enforcement cases, such as the False Claims Act (‘FCA”), needed to […]
Publications
Bipartisan Budget Act Helps Avoid Inadvertent Stark Violations (but Strengthens Penalties)
The Bipartisan Budget Act was signed into law by President Trump on February 9, 2018. While there are several health care features in the Act, this article focuses on two important changes: Stark In 2015, CMS included commentary in its Stark update that has helped avoid inadvertent violations of Stark. […]
105th Nebraska Legislature: Updated Activity on Bills of Interest
The Second Session of the 105th Nebraska Legislature convened on January 3, 2018. Bill introductions concluded on January 18, 2018. At the conclusion of bill introductions, we identified 20 bills warranting particular diligence. Summaries of these bills are available here. Below is an update of those bills that have had […]
105th Nebraska Legislature, Second Session
The Second Session of the 105th Nebraska Legislature convened on January 3, 2018. Bill introductions concluded on January 18, 2018. At the conclusion of bill introductions, we identified 20 bills warranting particular watchfulness. Summaries of these bills are available here. An updated chart of Second Session bills related to economic […]
DOL Reverses Course on Unpaid Interns and Withdrawn Opinion Letters
As often happens when a new administration of the opposite political party is installed, the Department of Labor (DOL) under President Trump made several announcements last month that evidence a shift in the agency’s enforcement policy. First, the DOL rescinded its 2010 guidance on when unpaid internships are acceptable under […]

