Articles and Blogs

On April 21, 2020, CMS issued explanatory guidance clarifying the scope and application of the previously issued Stark blanket waivers related to COVID-19 physician arrangements (“Waivers”). Our previous alert on the Waivers can be found here. Action and Timing The Waivers can be relied upon retroactive to March 1, 2020 but will terminate upon the... READ MORE

NATIONAL Biotech stocks surge as people are ‘hungry’ for good news on the coronavirus CMS sends $81B in advance payments to hospitals CMS calls for gradual return to elective procedures: 6 national COVID-19 updates FEMA releases COVID-19 resource for hospitals FEMA’s coronavirus response by the numbers: 33M masks, 56M respirators, 10,000 ventilators HHS Delays... READ MORE

Thursday, April 23 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ Congressional Outlook Today, the House approved an interim emergency spending measure that... READ MORE

On April 23, 2020, the Department of Treasury and the Internal Revenue Service issued proposed regulations related to the ‘silo’ rules for Unrelated Business Taxable Income (“UBTI”). Under Internal Revenue Code (“Code”) Section 512(a)(6), as added to the Code through the Tax Cuts and Jobs Act in 2017, tax-exempt organizations must calculate their UBTI... READ MORE

On April 23, the Department of Health and Human Services (“HHS”) outlined the basic framework for a new program to reimburse hospitals and other providers and suppliers for services provided to uninsured COVID-19 patients (for purposes of this article we refer to both providers and suppliers as “providers”). The framework for the program is... READ MORE

The Coronavirus Aid, Relief, and Economic Security Act (H.R. 748) (“CARES Act”) contains numerous provisions aimed at the response to the Coronavirus or COVID-19 pandemic, including $100 billion in reimbursement to hospitals and other health care entities for COVID‑19-related expenses and lost revenue (“Fund”). The First Tranche of the Fund was distributed on April... READ MORE

On Wednesday, April 22, 2020,  President Trump signed an executive order regarding immigration policies and enforcement amidst the COVID-19 pandemic titled “Suspension of Entry of Immigrants Who Present a Risk to the United States Labor Market During the Economic Recovery Following the 2019 Novel Coronavirus Outbreak” (the “Executive Order”). As we discussed with President... READ MORE

The Department of Treasury (“Department”) and Internal Revenue Service (“IRS”) have confirmed that tax-exempt organizations have an extension until July 15, 2020 to file their Forms 990-series annual information returns, as well as various other returns. While certain aspects of this relief are automatic, tax-exempt hospitals and other tax-exempt organizations should consider their particular... READ MORE

Wednesday, April 22 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ HHS Releases More Information on CARES Funding This afternoon HHS Secretary Alex... READ MORE

Hospitals across the country have been receiving emails from the Department of Health and Human Services (“HHS”) requesting hospitals to submit certain information about the number of COVID-19 patients admitted to the hospital through a portal established by an HHS vendor, TeleTracking. HHS stated that submitting this data will inform the decisionmaking on future... READ MORE