Articles and Blogs

Two proposed regulations under the Medicare & Medicaid EHR Incentive Program (“MU Program”) were submitted to the Office of Management and Budget (“OMB”) on December 31, 2014.  The two related proposed regulations relate to Stage 3 and the submission to OMB represents the first step toward the proposed regulations being published and available for review... READ MORE

This week, the Centers for Medicare & Medicaid Services (“CMS”) announced that it is extending the deadline for eligible hospitals and critical access hospitals (“CAHs”) to attest to meaningful use for the Medicare Electronic Health Record  Incentive Program for the 2014 reporting year from 11:59 PM EST on November 30, 2014 to 11:59 PM EST on December... READ MORE

On October 31, 2014, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released the Work Plan for Fiscal Year 2015 (“Work Plan”). The Work Plan confirms OIG will continue to concentrate a great deal of their enforcement efforts on the security and vulnerabilities of protected health information (“PHI”) contained... READ MORE

WEBINAR As we move into the second year of open enrollment through the Health Insurance Exchanges, it is time to revisit the issue of Premium Support Programs, an issue that had a bit of a rollercoaster ride during last year’s open enrollment. Has the dust settled enough that you can safely implement a Support... READ MORE

This week, the Centers for Medicare & Medicaid Services (“CMS”) announced its intent to reopen the submission period for hardship exception applications for eligible professionals and hospitals participating in the Medicare Meaningful Use Program in order to avoid the 2015 Medicare payment adjustments for not demonstrating meaningful use of Certified Electronic Health Record Technology (“CEHRT”).... READ MORE

On Tuesday, August 5, the Federal Communications Commission proposed changing how it defines high-speed Internet to download speeds of 10 megabits per second (Mbps) for a service to qualify as broadband. The FCC currently defines broadband Internet as 4 Mbps download speed. The FCC is seeking public comment on whether those bandwidth thresholds should be... READ MORE

Hospitals, health systems and other large users of Microsoft, Adobe and similar software are experiencing increased license auditing.  Because of the dynamic nature of the IT environment, most users operate in varying degrees of compliance with their license agreements.  In the event of an audit, the cost of compliance, known or unknown, can be... READ MORE

OCR Chief Regional Counsel for Region V, Jerome Meites, has warned that enforcement activity over the past year will “pale in comparison” to the next 12 months. While Mr. Meites was not specific as to this pronouncement being limited to Region V, it may be important to note that Region V covers Illinois, Indiana,... READ MORE

Following recent news about the Heartbleed exploit, CloudFlare, a San Francisco-based security services company, challenged hackers to use Heartbleed to get private encryption keys that would unlock secure data. It reported multiple winners to its challenge. By obtaining the private key for an SSL/TLS certificate, an attacker could set up a fake website that passes... READ MORE

Three federal regulators have released a long-awaited report proposing the framework for regulation of health information technology (“Health IT”).  The U.S. Food and Drug Administration (“FDA”), the Office of the National Coordinator for Health Information Technology (“ONC”) and the Federal Communications Commission (“FCC”) are accepting comments on their proposed risk-based regulatory framework until July... READ MORE