Articles and Blogs

Health care nonprofits and other qualified entities should submit applications for FEMA Public Assistance (“PA”) to support their COVID-19 responses as soon as possible. This funding will cover eligible protective measures for response efforts across the country. Recipients should heed FEMA’s guidance on applications as well as carefully document their protective measures from inception through…Read More

Many health care provider landlords are fielding requests from tenants for rent abatement or rent deferral as tenants face the negative economic effects of COVID-19. When those requests come from referral sources, landlords should exercise additional caution. This article explains the regulatory considerations behind the most common approaches to rent relief and provides best practices…Read More

In response to the COVID-19 pandemic, the Department of the Treasury and the Internal Revenue Service (“IRS”) recently issued several pieces of guidance this week on the various tax credits established for employers under the Families First Coronavirus Relief Act (“FFCRA”) and the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). Below is a…Read More

On April 2, 2020, the FCC released its Report and Order, establishing the rules for participation in its recently announced COVID-19 Telehealth Program (the “Program”). Through the Program, the FCC will provide eligible health care providers with 100 percent of the costs of the telecommunications, information services and connected devices (i.e. remote monitoring devices, such…Read More

Thursday, April 2 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 OCR Announces Notification of Enforcement Discretion HHS’s Office for Civil Rights (“OCR”)…Read More

Over the course of the past two weeks, the Federal Communications Commission (“FCC”) has undertaken several measures in an attempt to assist health care providers in light of the COVID-19 crisis, including by expanding funding opportunities available to eligible health care providers for telecommunications services and equipment and reducing the burden of participation in existing…Read More

An accepted doctrine of FCA pleading requires whistleblowers or the Government to assert an “objective falsehood” in their complaints. Last week, the Ninth Circuit nixed the requirement. The Ninth Circuit reversed a district court’s dismissal tied to a failure to plead an objective falsehood under FCA. The Court held that whistleblowers or the Government need…Read More

Wednesday, April 1 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.​ Major Hospital Associations Provide Recommendations to HHS on Distribution of Stimulus Funds In…Read More

On March 30, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued blanket waivers of the sanctions under Section 1877(g) of the Social Security Act and its regulations thereunder, more commonly known as the Stark Law. The waivers, which have a retroactive effect to March 1, 2020, will apply nationwide to financial relationships and…Read More