Articles and Blogs

Over the last year, health care providers (“Recipients”) have received billions of dollars in relief fund payments from the Provider Relief Fund (“Relief Fund”) created by the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) signed into law in March. Recipients of Relief Fund payments are required to comply with certain auditing and reporting…Read More

The Centers for Medicare & Medicaid Services (“CMS”) recently adopted its Final Rule (the “Final Rule”) modifications to the Stark Law aimed at modernizing and clarifying various regulations. Two such changes are universally relevant, but particularly so for those who practice in the health care real estate realm. For an overview of all changes in…Read More

Increasing numbers of hospitals and health systems are addressing social determinants of health in order to advance the health status of their communities. Among these efforts, the development of affordable housing is regarded as a key to improving the physical and mental health of a community’s low-income population. Consequently, many hospitals and health systems, either…Read More

On November 20, 2020, the Office of the Inspector General (“OIG”) and Centers for Medicare & Medicaid Services (“CMS”) issued final rules (the “Final Rules”) revising and expanding exceptions and safe harbors under the federal Stark Law (“Stark”) and Anti-Kickback Statute (“AKS”) as part of the Department of Health and Human Services’ “Regulatory Sprint to…Read More

On December 23, 2020, the Department of Health and Human Services Office of Inspector General (the “OIG”) issued Advisory Opinion No. 20-08 (the “Advisory Opinion”) addressing the use of gift cards to incentivize patients to utilize health care services. While gift cards themselves are not a new topic for the OIG in the area of…Read More

Effective on October 19, 2020, the Accreditation Commission for Health Care (“ACHC”) and the Accreditation Association for Hospitals/Health Systems (“AAHHS”) merged to form a single company in order to streamline accreditation and certification services for health care providers with various survey needs. AAHHS is the parent company of the Healthcare Facilities Accreditation Program (“HFAP”), the…Read More

Just three days before its effective date, the United States Court of Appeals for the District of Columbia affirmed the legality of the Department of Health and Human Services (“HHS”) price transparency rule requiring hospitals to publicly disclose the prices they charge for items and services, including their negotiated reimbursement rates with third-party payers (the…Read More