Articles and Blogs

Three and a half months ago, Congress included language in the National Defense Authorization Act (“NDAA”) declaring that TRICARE network providers will not be subject to OFCCP’s jurisdiction solely on the basis of their TRICARE network agreements.  The NDAA did not, however, address OFCCP coverage over health care providers in any other context, nor... READ MORE

The Office of Inspector General (“OIG”) issued its first opinion of 2012 on March 8th and posted it on its website yesterday.  In Advisory Opinion #12-01, the OIG issued a favorable opinion regarding a health system’s (“Health System”) proposal to form a wholly-owned group purchasing organization (“GPO”) to be the primary GPO for the... 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.    The U.S. Department of Health and Human Services (“HHS”) recently issued additional guidance regarding the essential health... READ MORE

On March 5, 2012, the Health Resources and Services Administration (“HRSA”) issued a new Program Notice (“Notice”) that provides additional insight into the recent audits of entities participating in the 340B Program (“Covered Entities”).  The Notice, which HRSA characterizes as a restatement of current policy, represents the clearest public statement to date of HRSA’s... READ MORE

On February 29, 2012, a federal judge lifted a temporary restraining order that had stopped the Drug Enforcement Agency (“DEA”) from enforcing the Immediate Suspension Order (“ISO”) it issued to Cardinal Health (“Cardinal”), a drug wholesale distributor, on February 3, 2012.  The ISO restricts Cardinal’s license to distribute controlled substances from its Lakeland, Florida... READ MORE

On Thursday, February 2, 2012, the Centers for Medicare and Medicaid Services (“CMS”) issued in the Federal Register its decision not to propose changes to the current Emergency Medical Treatment and Labor Act (“EMTALA”) regulations.  However, in this notice CMS is seeking additional comments on the applicability of hospitals with specialized capabilities to accept... READ MORE

Hall Render’s latest issue of the Employment Law Briefing summarizes these and other interesting developments: Now There Are Twenty-Three Speaking of developments, Indiana became the 23rd state to pass a Right to Work law.  That means that any agreement that requires employees to join a union or pay dues as a condition of employment is unlawful... READ MORE

HIPAA covered entities are required to submit reports of small breaches (impacting less than 500 individuals) that occurred during calendar year 2011 to the Office for Civil Rights (“OCR”) by February 29, 2012 pursuant to the HIPAA Breach Notification Rule.  Reports must be submitted electronically through OCR’s breach notification web page, which can be... 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. Twelve Attorneys General and a State Governor Support the Affordable Care Act Medicaid Expansion Provision On January... READ MORE

Consolidation continues to be the watchword in the health care industry.  Falling reimbursement, economies of scale, coordination of care and industry uncertainty drove provider consolidation in 2011 and will continue to drive provider consolidation in 2012.  As hospitals and physicians look to position themselves strategically for a post-health care reform world, the pace of... READ MORE