For years, we have been tracking the Department of Labor’s Office of Federal Contract Compliance Programs’ (“OFCCP”) efforts to expand its jurisdiction to health care employers. Generally, the OFCCP enforces regulations that require employers with at least 50 employees, who hold a single contract or subcontract of at least $50,000 […]
Publications
A Continued Challenge: The 3-Day Payment Rule Timeline
The Centers for Medicare and Medicaid Services’ 3-day and 1-day payment rules (the “Payment Rules”) continue to generate many questions among health care providers and suppliers concerning effective dates, changes, and application of the Payment Rules. Under the Payment Rules, a hospital (or an entity that is wholly owned or […]
OIG’s Update to the Provider Self-Disclosure Protocol Offers Expanded Detail and Transparency
The updated Provider Self- Disclosure Protocol (SDP) issued April 17, 2013 by the OIG expanded and updated the original SDP issued on October 30, 1998 and the OIG’s Open Letters to health care providers issued subsequent to the original SDP. Both the original and the updated SDP provide guidance on […]
Flood Insurance Could Bring Flood of Anti-Servicer or Anti-Mortgagee Litigation
Spring rains help flowers bloom but also bring to mind possibilities of freshwater floods. Flood insurance definitely has its place in prudent mortgage lending. Mishandling of flood insurance covenants by a mortgage loan servicer or mortgagee, however, can lead to a “flood” of anti-servicer or anti-mortgagee litigation. Read on for […]
A Will for your Avatar: Estate Planning for Digital Assets
When obtaining an estate plan, people generally have the goal of passing their real and personal property in an orderly way according to their wishes. However, as the world’s business and activities are increasingly conducted electronically, people generally neglect to form a plan to deal with some of the assets […]

