Articles and Blogs

A pair of final rules were published May 1, 2020, by HHS. The first rule issued by the Office of the National Coordinator for Health IT (“ONC”) relates to the 21st Century Cures Act information blocking provisions and the ONC Health IT certification program (“Info Blocking Regulations”). The second rule issued by CMS relates to…Read More

Thursday, May 28 Update Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. Going forward, these updates will be distributed as developments warrant instead of nightly. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. Note – ​we believe this is the…Read More

On May 26, 2020, OIG released its Strategic Plan for Oversight of COVID-19 Response and Recovery (“Strategic Plan”). The Strategic Plan lays out OIG’s priorities for ensuring that HHS’s COVID-19 relief funds are appropriately disbursed and used, and it gives insights into the enforcement activities that relief fund recipients can expect to see going forward….Read More

Skilled nursing facilities (“SNFs”) have two new areas of focus from the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) – infection control and tracking their use of CARES Act provider relief funds. OIG Work Plan Update: Infection Control Recently, the OIG updated its Work Plan, to add audit of nursing…Read More

Tuesday, May 26 Update Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. Going forward, these updates will be distributed as developments warrant instead of nightly. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. Note – ​we believe this is the…Read More

The events caused by COVID-19 and the pandemic’s ripple effects has certainly caused pause and required a renewed approach to most of life’s activities. Shockingly, legal due diligence conducted in a health care M&A transaction is not immune from such pause and reassessment. New considerations of novel or previously dormant factors will be required in…Read More

Over the last several months, health care providers have seen COVID-19 relief funds in various forms, from advances against future payments, to pure grant money. In addition to the much-needed assistance these funds have provided, a new stream of revenue has emerged that must be accounted for, and ultimately negotiated, in a health care transaction….Read More

In a press release posted after 6:00 P.M. EDT on May 22, 2020, the Department of Health and Human Services (“HHS”) announced that it is AGAIN extending the deadline for providers and suppliers (collectively “Providers”) to attest to receipt of payments from the CARES Act Provider Relief Fund and accepting the related Terms and Conditions….Read More

For the third time this week, twice on May 20 and again late on the 21, the Department of Health and Human Services (“HHS”) has amended its Frequently Asked Questions (“FAQs”) related to the CARES Act Provider Relief Fund. These FAQs continue to build on its recent guidance related to common health care industry transactions….Read More