Articles and Blogs

Background On November 26, 2012, the Office for Civil Rights (“OCR”) released guidance regarding methods and approaches to achieve de-identification of protected health information (“PHI”) in accordance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).  Congress mandated in the American Recovery and Reinvestment Act of 2009 that OCR issue such guidance. READ MORE

Executive Summary On December 20, 2012, a Federal District Court judge allowed a False Claims Act (“FCA”) case to continue against a Pharmacy Benefits Manager1 (“PBM”), related to PBM services it furnished to an unrelated Medicare Part D Sponsor (“Sponsor”).  In 2007, the Sponsor engaged a third party auditor to audit the Part D... READ MORE

On January 1, 2013, the Senate and House approved the American Taxpayer Relief Act of 2012 (the “Act”), which contains good news for charities as it provides a tax benefit for some taxpayers if they act by January 31, 2013.  The Act also revives the Individual Retirement Account (“IRA”) charitable rollover in IRC Section... READ MORE

The Medicare therapy caps have been the subject of many changes over the past couple of years, and several of those changes were set to expire on December 31, 2012.  However, due to the passage of the American Taxpayer Relief Act of 2012 (the “Act”), some of the changes will be extended until the... READ MORE

Late last night, Congress approved a bill to avoid the widespread tax increases and 2% across-the-board spending cuts known as the “fiscal cliff.”  While the legislation permanently raises taxes on individuals with incomes over $400,000 and couples making over $450,000, it only delays the 2% across-the-board spending cuts (including Medicare reimbursements) for two months... READ MORE

READ MORE

READ MORE

READ MORE

READ MORE

Overview and Executive Summary On Friday, December 21, 2012, the Drug Enforcement Administration (“DEA”) released an important proposed rule governing the secure disposal of unused controlled substances.  This rule (the “Proposed Rule”) was developed to implement provisions of the Secure and Responsible Drug Disposal Act of 2010 (“Disposal Act”) and proposes a number of... READ MORE