Articles and Blogs

On November 4, CMS released its Interim Final Rule (“IFR”) requiring COVID-19 vaccinations for individuals working in Medicare- and Medicaid-participating facilities, as well as individuals working in certain other settings involving face-to-face interactions with patients.  The IFR requires all clinical and non-clinical personnel working within a Medicare and Medicaid participating facility or other applicable setting…Read More

On September 30, 2021, the Departments of Health and Human Services (“HHS”), Labor and Treasury and the Office of Personnel Management (collectively, the “Departments”) published the second interim final rule implementing certain provisions of the No Surprises Act (“Part II of the IFR”). Part II of the IFR addresses key aspects of the No Surprises…Read More

On September 30, 2021, the Departments of Health and Human Services (“HHS”), Labor, and Treasury and the Office of Personnel Management (collectively, the “Departments”) published the second interim final rule implementing certain provisions of the No Surprises Act (“Part II of the IFR”). Part II of the IFR addresses key aspects of the No Surprises…Read More

There are currently a number of restrictions regarding international travel due to the ongoing COVID-19 pandemic. This has led to the blanket recommendation to advise your foreign national employees to refrain from departing the United States or they risk being abroad for longer than anticipated, which can ultimately affect their U.S. employment. This recommendation over…Read More

As Hall Render detailed last month, President Biden announced the need for new COVID-19 vaccination rules. An Emergency Temporary Standard (“ETS”) from the Occupational Safety and Health Administration (“OSHA”) will require vaccinations or weekly testing for employees of employers with 100 or more employees. We also noted that CMS announced its intention to issue an…Read More

The health care industry has experienced significant increases in cyber-attacks such as ransomware the past few years. One segment of the industry that may be impacted especially hard by these increased attacks is Critical Access Hospitals (“CAHs”). Due to the increasing number of cyber-attacks, insurance underwriting practices are shifting. Instead of virtually rubberstamping each application for…Read More

On October 7, 2021, five years after issuing initial draft guidance on its enforcement approach for hospitals and health system pharmacy compounding under section 503A of the Food, Drug, and Cosmetic Act (the “Act”), the U.S. Food and Drug Administration (“FDA”) released revised draft guidance (“Draft Guidance”) that provides increased flexibility to hospitals and health systems…Read More

On Monday, October 11, Texas Governor Greg Abbott issued Executive Order GA-40, requiring that employers provide exemption from any COVID-19 mandate for reason of personal conscience, religious belief or for medical reason, including prior recovery from COVID-19. These exemptions are broader than those required under Title VII of the Civil Rights Act (for sincerely held…Read More