Publications

The CFPB’s latest “Supervisory Highlights” Report provides some useful information relating to the regulator’s recent supervisory actions and highlights areas of focus related to compliance management systems, mortgage servicing and fair lending.   Compliance Management Systems The CFPB has long taken the position that compliance management is vital to prevention […]

Although the federal government recently postponed payment reviews for the new “two-midnight” rule, hospitals should prepare now for the approaching January 1, 2014 date, when reviews will resume. The two-midnight rule refers to an important clarification from the Centers for Medicare & Medicaid Services (CMS), in the FY 2014 IPPS […]

The Centers for Medicare and Medicaid Services (“CMS”) recently released eight frequently asked questions concerning the Self-Referral Disclosure Protocol (“SRDP”). The SRDP is a product of the Patient Protection and Affordable Care Act of 2010 and provides a process for providers and suppliers to self-disclose violations of the physician self-referral […]

The Office for Civil Rights recently published new guidance to assist law enforcement and covered entities when addressing information sharing situations where the HIPAA Privacy Rule may be at issue. The HIPAA Guide for Law Enforcement contains an overview of the Privacy Rule and describes permitted disclosures of health information […]

The Federal Reserve has appealed a district court decision that would have vacated the Fed’s Regulation II, which implements the Dodd-Frank Act’s interchange fee cap and dual routing rule for debit cards.   On July 31, 2013, the United States District Court for the District of Columbia issued an opinion […]