Articles and Blogs

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

Review of the New Home Health Conditions of Participation – Patient Rights (part 2). This is the fifth 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 proposed to make to the home health... READ MORE

On Monday, January 30, 2017, the Department of Health and Human Services Health Resources and Services Administration (“HRSA”) withdrew its 340B Program Omnibus Guidance, also referred to as the “Mega-Guidance.” The guidance would have addressed questions and provided clarifications for enrolled covered entities, drug manufacturers and contract pharmacies participating in the 340B Program. The... READ MORE

On Friday, January 27, 2017, President Trump signed a third executive order dealing with immigration titled, “Protecting the Nation from Foreign Terrorist Entry into the United States.” The provisions contained in the order impose a 90-day ban on entry for all nationals of seven named countries. The order also imposes a halt for all... READ MORE

Review of the New Home Health Conditions of Participation – Patient Rights. This is the fourth 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 proposed to make to the home health CoPs in... READ MORE

On January 18, 2017, Senate Bill 33 (“SB 33”) was introduced in the Michigan Senate by Senator Kenneth Horn (R – Frankenmuth). SB 33 would amend the Michigan penal code by imposing felony charges against any individual who assaults, batters, wounds, resists, obstructs, opposes or endangers emergency room personnel performing their duties. The current... READ MORE

On January 23, 2017, following a 13-day trial, the U.S. District Court for the District of Columbia (the “Court”) ruled in favor of the U.S. Department of Justice (“DOJ”) in the government’s suit to block the $37 billion insurance mega merger between Aetna Inc. (“Aetna”) and Humana Inc. (“Humana”). It is expected that a... READ MORE

As you may know, President Trump signed a pair of executive orders recently regarding immigration policies and enforcement. While his orders may have a sweeping effect on immigration as a whole, employment-based immigration processes are not overtly changed. Below is a brief summary of provisions of the executive orders and the draft order that... READ MORE