Articles and Blogs

The 2011 Form 990, Schedule K has added a question asking whether or not written procedures have been adopted to ensure violations are timely identified and corrected through the IRS’s Voluntary Closing Agreement Program (“VCAP”) if self-remediation is not available.  See our February 2012 Summary of 2011 Schedule K changes, here.  As this question... READ MORE

On Tuesday, June 19, 2012, the Health Resources and Services Administration (“HRSA”) released new guidance related to the current ongoing 340B Program covered entity audits (“340B Audit Guidance”). Although this guidance is consistent with other related audit information communicated verbally and in writing by HRSA, it does provide additional clarity regarding the pre-audit, onsite... READ MORE

Summary On June 15, 2012, the Director of the Survey and Certification Group of the Centers for Medicare and Medicaid Services (“CMS”) issued a memorandum (“Memo”) to state survey agency directors instructing them to hold off on enforcing a recently revised hospital governing body condition of participation (“CoP”) requiring the governing body of each... READ MORE

This installment of Hall Render’s Health Law Broadcast series on health care reform is designed to provide you with the insight, analysis and practical suggestions with respect to the various reform initiatives that will affect your organization. On May 11, 2012, the Centers for Medicare and Medicaid Services (“CMS”) published a proposed rule (“Proposed... READ MORE

The second wave of the HIPAA Security and Privacy Audit Program conducted by the HHS Office for Civil Rights (OCR) is underway.  Linda Sanches, the Lead for HIPAA Compliance Audits for the OCR, provided a detailed update on the Audit Program at the fifth annual Safeguarding Health Information: Building Assurance through HIPAA Security conference... READ MORE

Hall Render has learned the Supreme Court will not issue an opinion on the constitutionality of the Affordable Care Act this week. Sources at the Court tell Hall Render the earliest the Court might rule on the landmark health care law is Monday, June 18. READ MORE

The Center for Medicare and Medicaid Innovation (Innovation Center) is set to announce today it is testing the Advance Payment Accountable Care Organization (ACO) Model for participants in the Medicare Shared Savings Program. The Shared Savings Program provides incentives for participating health care providers who agree to work together and become accountable for coordinating... READ MORE

This installment of Hall Render’s Health Law Broadcast series on health care reform is designed to provide you with the insight, analysis and practical suggestions with respect to the various reform initiatives that will affect your organization.  IRS Issues Guidance on $2,500 Limit for Health Flexible Spending Accounts  The IRS recently issued Notice 2012-40 providing... READ MORE

State attorneys general are beginning to focus their attention on health care privacy laws under the authority granted to them by the Health Information Technology for Economic and Clinical Health Act (“HITECH”) and state consumer laws.  On May 24, 2012, Massachusetts Attorney General Martha Coakley announced the filing of a final judgment with a... READ MORE

On May 11, 2012, the Centers for Medicare and Medicaid Services (“CMS”) issued the 2013 Inpatient Prospective Payment System (“IPPS”) Proposed Rule.  In the IPPS Proposed Rule, CMS proposed to change the rules for: Calculating new teaching hospital full-time equivalent cap (“FTE cap”) by moving from a 3-year window to a 5-year window; What... READ MORE