Publications

A new safe harbor under the Anti-Kickback Statute (“AKS”) permits providers to offer free or discounted transportation services to patients.  The safe harbor permits both direct transportation offered to individuals, and shuttle services that follow a regular route, subject to a number of conditions. The conditions for the safe harbor […]

Since its original adoption in 1982, Securities and Exchange Commission (“SEC”) Regulation D, Rule 504 has been limited in amount to the issuance of no more than $1 million in securities in a 12-month period. Effective January 20, 2017, the SEC increased the maximum offering amount to $5 million in […]

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 […]

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 […]

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 […]