Publications

At long last, the Office of Management and Budget (OMB) approved final rules extending the sunset on the Stark exception and an Anti-Kickback safe harbor. As addressed previously in this Health Law Advisory article, both the exception and the safe harbor were scheduled to sunset on December 31, 2013. This […]

With rising interest rates looming somewhere on the horizon, the FDIC has re-emphasized the importance of appropriate interest-rate risk oversight and risk management processes to ensure that banks are positioned to avoid or mitigate risks inherently associated with rising rates.1   FDIC Concerns The FDIC is concerned that certain institutions […]

In a technical assistance letter (“TAL”) from September 6, 2013, the Office of Special Counsel (“OSC”) reaffirmed its warning against asking job applicants to specify their citizenship status during the application process. The OSC noted that rejected applicants may believe that the employer used such information to discriminate against them […]

Although it includes nine pages of instructions and a lengthy handbook of over seventy pages, there are five things about the Form I-9 that every HR person should know to avoid severe penalties in the event of an audit by Homeland Security Investigations or ICE. While following the tips below […]

In 2006, CMS and the OIG promulgated a Stark exception and an Anti-Kickback safe harbor to encourage the development and adoption of interoperable electronic health record systems in communities. The exception and safe harbor allowed hospitals to donate up to 85 percent of the cost of EHR software and training […]