Articles and Blogs

The Wisconsin Medical Examining Board (“MEB”), on January 27, 2017, filed with the Wisconsin Legislature a proposed administrative rule governing the practice of medicine using telemedicine (“Med 24”). Upon the completion of the legislative review and approval process and final publication by the MEB, Med 24 will delineate standards that apply to a physician... READ MORE

In continuation of its active beginning to the new year, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced on February 1, 2017, that it imposed a HIPAA civil money penalty of $3.2 million on a Texas medical center (“Medical Center”). OCR issued the penalty for wrongful disclosure of... READ MORE

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Price Confirmation Expected to Expedite ACA Replacement Process After hours of contentious debate, the Senate confirmed Rep. Tom Price, M.D. (R-GA) as the next Secretary of Health and Human Services in the early morning hours of February 10. One of Price’s first tasks will be to release the ACA replacement proposal promised by President... READ MORE

On February 3, 2017, President Donald Trump signed a presidential memorandum addressing the Department of Labor’s (“DOL”) so-called fiduciary rule that will go into effect on April 10, 2017.  Early media reports on February 2 and 3 indicated that the president would delay or suspend the rule. However, he did neither. The presidential memorandum directs... READ MORE

On January 3, 2017, Michigan Lieutenant Governor Brian Calley signed Senate Bills 1015 and 1016 (collectively, the “Act”), which require applied behavior analysts to be licensed similarly to other professionals in the medical field. In an analysis of the Act, the Michigan Senate Fiscal Agency reasoned that early intervention using evidence-based treatment has shown... READ MORE

On January 17, 2017, the IRS released Revenue Procedure 2017-13 (“Rev. Proc. 17-13”) regarding private business use safe harbors for management and service contracts that affect assets financed with tax-exempt bond proceeds. Rev. Proc. 17-13 modifies, amplifies and supersedes safe harbors Revenue Procedure 2016-44 (“Rev. Proc. 16-44”), which we discussed here, and which in turn had... READ MORE

The opioid epidemic has garnered widespread attention and action both nationally and at the state level. The Wisconsin Legislature, Governor and administrative agencies continue to take actions to address the significant challenges of opioid overdose, misuse and abuse in Wisconsin. A number of the state initiatives aimed at combating these problems focus on the... READ MORE

Review of the New Home Health Conditions of Participation – Emergency Preparedness, Organization and Administration of Services, Personnel Qualifications and Clinical Records. This is the sixth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they... READ MORE

Republicans Signal Slower Pace for ACA Repeal While Replacement Package Still Unclear Republicans on Capitol Hill signaled this week that repeal of the Affordable Care Act (“ACA”) may not happen as fast as they promised, and reports indicate they are no closer to consensus on a replacement package. After a contentious retreat in Philadelphia... READ MORE