Publications

Two years ago, in September, 2012, the U.S. Attorney General and the Secretary of Health and Human Services issued a joint letter seeking cooperation from the America Hospital Association and other health care associations, to ensure that electronic health records (EHR) were not used to inflate claims to the Medicare […]

The Eighth Circuit Court of Appeals recently held that a spouse-guarantor cannot use the Equal Credit Opportunity Act (“ECOA”) as an affirmative defense to a collection action based on their guaranty. I. ECOA Prohibits Discrimination Against “Applicants” Based On Marital Status A. ECOA bans creditor from requiring a spouse to […]

Money 20/20, a leading payments conference, concluded last week after more than 7,000 payments industry representatives gathered to discuss the rapidly evolving payments landscape. A wide array of emerging issues were discussed and debated, a few of which we would like to highlight here: Apple Pay. Much fanfare accompanied the […]

The Consumer Financial Protection Bureau (“CFPB”) announced early this morning that it is proposing new federal rules for the prepaid market in a Notice of Proposed Rule Making (“NPRM”) to be released later today. The NPRM will affect a variety of prepaid products and will include provisions requiring consumer protections […]

On October 3, 2014, the Office of Inspector General of the Department of Health and Human Services (“OIG”) released a proposed rule expanding safe harbors under the anti-kickback statute and clarifying the exceptions to “remuneration” under the Civil Monetary Penalties (“CMP”)/beneficiary inducement laws. The proposed rules respond to longstanding concerns […]