Prior to the enactment of the Patient Protection and Affordable Care Act (the “Act”), CMS had no express authority to negotiate settlements of, and reduce the liabilities associated with, Stark violations. Providers had two alternatives: (i) the provider could repay the entire amount paid by Medicare as a result of […]
Publications
Nebraska Department of Revenue Publishes Guidance on Historic Tax Credits
The Nebraska Department of Revenue (the “Department”) recently issued guidance on calculating eligible expenditures for earning state historic tax credits under the Nebraska Job Creation and Mainstreet Revitalization Act (the “Act”). The Act provides $15 million in tax credits annually for applicants rehabilitating historically significant property to offset Nebraska income […]
Federal Contractor Privacy Training Now Required
On December 20, 2017, the U.S. Department of Defense (DOD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA), issued a Final Rule that requires federal contractors to follow new privacy training procedures with regard to handling and protecting “personally identifiable information” or “PII.” PII refers to any […]
Federal Contractor Update
There are lots of Federal Contractor odds and ends to discuss since President Trump’s inauguration. Let’s get caught up! Trump Signs Executive Order to Roll Back Regulations In late January 2017, President Trump signed an Executive Order to eliminate two federal regulations for every one regulation enacted. Given the numerous […]
A Peer Review Reminder: How to Treat Contextual Information
A recent Illinois case highlights a dilemma that medical staffs often face when taking corrective action against peers, namely, whether and how to consider the physician’s prior history as context for new concerns. The case also reinforces the principle that the role of courts is typically limited to determining whether […]

