Articles and Blogs

On March 30, 2020, CMS issued a pre-publication copy of its “Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (“PHE”)” Interim Final Rule (“Rule”). This Rule addresses regulatory changes to Medicare and Medicaid intended to help Medicare providers during the COVID-19 Pandemic. The Rule includes several changes to Medicare’s Home Health…Read More

Tuesday, March 31 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ HHS, FEMA Create Supply Chain Task Force HHS and the Federal Emergency Management…Read More

On March 30, 2020, OIG released a message to health care providers reinforcing OIG’s continued focus on aggressively pursuing bad actors exploiting the COVID-19 crisis but also praising the hard work and dedication of the frontline providers who are serving heroically in this crisis. This is in follow-up to our previous COVID-19-related guidance pertaining to…Read More

The Telephone Consumer Protection Act (“TCPA”) generally prohibits the use of automated text messages or prerecorded calls to a cellular number without the prior consent of the receiving party. The TCPA expressly excepts from the foregoing prohibition any calls or messages sent for “emergency purposes.” See 47 C.F.R. § 64.1200(f)(4). In a Declaratory Ruling made…Read More

On March 30, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued blanket waivers of several Stark Law requirements related to COVID-19 physician arrangements. These waivers are welcome news to hospitals, health systems and other providers that have been tackling challenging physician contracting, compensation and staffing issues over the past month. Timeframe The Stark…Read More

On March 23, 2020, Centers for Medicare & Medicaid Services (“CMS”) announced the preliminary results of a recent survey of a nursing home in Kirkland, Washington, the epicenter of the COVID-19 outbreak in Washington. According to a Centers for Disease Control and Prevention (“CDC”) report, 81 residents, 34 staff and 14 visitors also became ill…Read More

Monday, March 30 Recap Note – ​We believe this is the most up-to-date information available at this time, but it is subject to change ​as circumstances warrant. Also, all finalized resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website.​ CMS Updates Waivers & Flexibilities Late this afternoon, CMS updated the waivers and…Read More

On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), a $2.2 trillion stimulus package intended to spread relief across the American economy during the COVID-19 public health emergency. Title II of the CARES Act provides monetary relief for workers affected by COVID-19 by both increasing…Read More

In an effort to ensure that America’s clinical laboratories are prepared to respond to the COVID-19 pandemic, CMS issued a memo providing guidance during these uncertain times. In their discretion, CMS issued guidance on: (1) how pathologists may review pathology slides remotely; (2) the expedited review of CLIA applications; (3) the use of one CLIA…Read More

As COVID-19 continues to spread rapidly across the United States, emergency departments regardless of hospital size or location are being inundated with patients seeking emergency care. Providers have begun to question how they can fulfill their obligations to perform emergency screenings, stabilization and transfers in compliance with the Emergency Medical Treatment and Labor Act (“EMTALA”)….Read More