Articles and Blogs

On Tuesday, May 21, 2013, the Department of Health and Human Services (“HHS”) announced that it had reached a settlement with a State University (“University”) arising out of alleged violations of the Security Rule under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). The settlement comes after an HHS Office for Civil... READ MORE

Executive Summary On April 26, 2013 CMS released proposed rules for implementing Section 3133 of the Affordable Care Act (“ACA”).  Starting in 2014, these proposed rules will begin a series of substantial reductions in Disproportionate Share Hospital (“DSH”) payments to hospitals.  Most payments under the new DSH program will be from a set pool... READ MORE

Executive Summary On May 8, 2013, the Department of Health and Human Services Office of Inspector General (“OIG”) issued an updated version of its Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (“Updated Bulletin”).  In September of 1999, the OIG published its original bulletin on this topic... READ MORE

On Tuesday, April 30, 2013, U.S. Customs and Border Protection (“CBP”) began implementing an automated version of Form I-94, Arrival/Departure Record, at air and sea ports of entry.  Form I-94 provides foreign travelers with evidence that they have been lawfully admitted to the United States, which is necessary to verify alien registration, immigration status... READ MORE

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“Daily deal” websites that offer discounted products and services are becoming more and more popular among health care providers for their ability to bring in new patients and attract attention among existing patients. It is estimated that one out of every eleven deals offered by daily deal websites are offering discounts on medical procedures, including... READ MORE

Summary On Wednesday, May 1, 2013, the U.S. Department of Justice (“DOJ”) announced that it had reached a settlement with a two-hospital, Montana-based health system (“System”) arising from financial relationships between the System and a combination of 139 employed and independent physicians and physician groups.  Under the terms of the Settlement Agreement, the System... READ MORE

The graduate medical education (“GME”) landscape continues to evolve, even as the basic structure of Medicare GME reimbursement remains in place. Recently, noteworthy proposals and changes include proposed legislation that would provide for 15,000 new residency positions over five years to increase the number of residents in training and a change to the regulations that... READ MORE

Executive Summary On April 17, 2013, the Office of Inspector General (“OIG”) issued an updated version of its Self-Disclosure Protocol (“Protocol”).  In 1998, the OIG published the original Protocol to establish a process for health care providers to voluntarily identify, disclose and resolve instances of potential fraud involving federal health care programs, particularly with... READ MORE

The U.S. Food and Drug Administration (“FDA”) wants to give manufacturers of medical devices in vitro diagnostics (“IVDs”) and biological products the authority to use certain symbols and images on their product labeling to convey safety information and instructions for use. A proposed rule published April 19 would revise the agency’s regulations at 21... READ MORE