Tax-exempt hospitals are required by section 501(r) of the Internal Revenue Code to perform a community health needs assessment (“CHNA”) at least once every three years. Tax-exempt hospitals must both perform and complete a CHNA and formally adopt an implementation strategy based on the CHNA by the end of their […]
Publications
OCR Launches Nationwide Compliance Review of CAH Language Access Programs
On April 30th, the Office of Civil Rights (OCR) announced that it will begin compliance reviews to support language access programs in critical access hospitals (CAHs) as part of federal efforts to reduce health disparities. OCR reviews will focus on compliance with Title VI of the Civil Rights Act of […]
Idaho State University Fined $400,000 for HIPAA Security Rule Violation
In August 2010, the Idaho State University notifi ed the HHS Office for Civil Rights (the “OCR”) that, after they performed routine server maintenance for their Pocatello Family Medicine Clinic, technicians failed to put the server firewall back into place. This left the protected health information on 17,500 patients exposed […]
OIG Exclusion Update: The Who, What, When, Where, and Why
The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently released an updated Special Advisory Bulletin1 covering the scope and effect of exclusion from Federal health care programs. The updated bulletin replaces and supersedes the OIG’s 1999 Special Advisory Bulletin on the effect of exclusion, and […]
FDIC/OCC Issue Proposed Guidance on Deposit Advance Products
On April 24, 2013, the CFPB released a white paper of initial data findings regarding a study the CFPB conducted into payday loans and deposit advance products.1 Based on its findings, the CFPB concluded that these products were harmful to consumers because they are provided without adequate analysis into an […]