Articles and Blogs

Executive Summary On January 31, 2014, the Department of Health and Human Services Office of Inspector General (“OIG”) released its Work Plan for Fiscal Year 2014 (“Plan”).  The Plan provides insight into the OIG’s potential audit and enforcement activities for the next fiscal year.  While the Plan addresses several different provider types, this article... READ MORE

2-Midnight Rule Enforcement Delayed Until October 1, 2014 On January 31, 2014, the Centers for Medicare and Medicaid Services (“CMS”) announced another delay in enforcement of the 2-Midnight Rule, now pushed back to October 1, 2014.  The delay provides additional time for CMS to educate hospitals on how to implement the 2-Midnight Rule, which has... READ MORE

Under the Breach Notification Rule, HIPAA covered entities are required to submit reports of certain breaches of unsecured protected health information (“PHI”) affecting fewer than 500 individuals to the Office for Civil Rights (“OCR”) on an annual basis.  No later than March 1, 2014, covered entities must submit their breaches electronically through OCR’s breach... READ MORE

“Your leadership style is not in accordance with company practices.” This is what an HR Director was told when he was terminated after his company learned that he was “stressing out” two of his assistant HR managers.  The tense work environment that he created caused both managers to seek counseling and each had begun... READ MORE

Executive Summary On February 6, 2014, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule amending the Clinical Laboratory Improvement Amendments of 1988 (“CLIA”) and the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) to provide patients with the right to access test reports directly from clinical laboratories subject to... READ MORE

Are you a Physician-Owned Hospital? Have you submitted your Hospital’s annual ownership and investment interest reporting data? Do you know that Physician-Owned Hospitals have until March 1, 2014 to report ownership and investment information required by the Affordable Care Act? READ MORE

Recently, the Medicare Payment Advisory Commission (“MedPAC”) recommended that Congress reduce or eliminate the Medicare reimbursement differences between hospital-based departments and freestanding physician practices for certain services.  If Congress enacts legislation based on this recommendation, hospitals could see a decrease in Medicare revenue of 0.6% or $1.1 billion per year. READ MORE

Executive Summary Recently, legislation was introduced in Congress that seeks to combat the growing problem of prescription drug abuse.  United States Representative Gus Bilirakis (R-FL), along with his co-sponsor Representative Ben Lujan (D-NM), introduced H.R. 3392, the Medicare Part D Patient Safety and Drug Abuse Prevention Act of 2013, in a bipartisan effort to... READ MORE

Executive Summary On January 31, 2014, the Office of Inspector General (“OIG”) published its Work Plan for Fiscal Year (“FY”) 2014.  Normally, the OIG issues its Work Plan in early October to coincide with the beginning of its October 1 Fiscal Year. The Work Plan, which is published annually and describes the OIG’s new and... READ MORE

New TJC Standards Addressing Patient Flow and Boarding Citing a recent American College of Emergency Physicians state-by-state report card that gave the nation as a whole a “D+” in emergency department care, Modern Healthcare proclaimed the worsening state of the “emergency-care environment” a consequence of “increased demand and shrinking resources.”1  The decline in emergency department care... READ MORE