Articles and Blogs

Earlier this year, the Food and Drug Administration (“FDA”) announced a Proposed Rule regarding national standards for the licensing of prescription drug wholesale distributors (“Wholesale Distributors”) and third-party logistics providers (“3PLs”). The proposed regulation is issued pursuant to requirements for national regulatory standards under the Drug Supply Chain Security Act (“DSCSA”), which is part of…Read More

Our Health Care Real Estate Briefing is your comprehensive summary of weekly health care real estate highlights happening across the nation. Last week, the American Hospital Association released a report on the impact of COVID-19 on hospitals’ operating margins. The cost of staffing, drugs and supplies have had a significant impact on hospital margins. Legislators…Read More

Recently, the Department of Health and Human Services Office of Inspector General (“OIG”) issued Advisory Opinion No. 22-08 (the “Advisory Opinion”), approving a federally qualified health center’s (“FQHC’s”) provision of “locked” smartphones and chargers to existing patients in order to promote access to telehealth services (the “Arrangement”). Background The FQHC primarily serves low-income individuals, certifying…Read More

Effective May 4, 2022, certain foreign nationals who timely filed to renew their Employment Authorization Document (“EAD”) will receive an automatic extension of the period of employment authorization up to 540 days beyond the original expiration date. This is an effort by U.S. Citizenship and Immigration Services (“USCIS”) to temporarily alleviate the current situation involving…Read More

Indiana’s Build-Operate-Transfer Statute For political subdivisions in Indiana considering pursuing a public-private partnership for the development, design and construction of public facilities, build‑operate‑transfer (“BOT”) is rapidly becoming the “go-to” procurement and delivery method. Subject to satisfaction of the procedural requirements set forth in Indiana Code §5-23 et seq. (“BOT Statute”), which governs BOT transactions, the…Read More

On March 28, 2022, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced the resolution of two more complaints under its Right of Access Initiative. This brings the total number of cases to 27 since the initiative was first announced in 2019, with financial liability imposed on covered entities ranging…Read More

Our Health Care Real Estate Briefing is your comprehensive summary of weekly health care real estate highlights happening across the nation. Over the last few weeks, the Biden Administration and CMS have released ownership data for skilled nursing facilities (“SNFs”). The goal, according to the Administration, is to add transparency to SNF ownership and to…Read More

The United States Department of Health and Human Services Office for Civil Rights (“OCR”) announced a settlement with a dental practice (“Practice”) which has agreed to pay $62,500 to settle potential violations of the HIPAA Privacy Rule, as well as to take corrective action after impermissibly disclosing patient PHI to a political campaign manager and…Read More