Articles and Blogs

On March 27, 2017, the Michigan State Legislature revised the telehealth services regulations that were enacted on December 21, 2016. This revision to MCL 333.16285 goes into effect on March 29, 2017 and will allow health care professionals providing telehealth services to prescribe controlled substances. The original regulations prohibited prescription of controlled substances; however, stakeholders…Read More

On March 15, 2017, the U.S. District Court for the Western District of Pennsylvania provided the first federal court interpretation of the writing requirements affecting several regulatory exceptions in the federal physician self-referral statute (“Stark Law”) and its implementing regulations since the Centers for Medicare & Medicaid Services (“CMS”) provided sweeping revisions and clarifications to…Read More

On March 27, 2017, the Office of Inspector General for the U.S. Department of Health and Human Services (“OIG”) issued a resource guide to assist health care organizations in assessing the effectiveness of their compliance programs (“Resource Guide”). OIG developed the Resource Guide in collaboration with 30 health care compliance professionals through a collaborative effort…Read More

This is the fifth article in a series on the 21st Century Cures Act (the “Cures Act”), which was signed into law on December 13, 2016. We will continue publishing a series of articles summarizing various components under the Cures Act. The articles in our series are located here. This article highlights the opportunities created…Read More

American Health Care Act Pulled Just Before House Vote Despite a last minute lobbying effort by President Trump, the Republican leadership in the House pulled the American Health Care Act (“AHCA”) off the floor minutes before a vote was scheduled to take place when it became evident there weren’t enough votes for it to pass….Read More

On March 20, 2017, the Food and Drug Administration (“FDA”) published a notice in the Federal Register delaying the implementation of the final rule (“Final Rule”) regulating off-label drug promotion until March 19, 2018. The Final Rule was published in the Federal Register of January 9, 2017. The effective date was originally delayed until March…Read More

On February 8, 2017, the U.S. District Court for the District of Columbia (the “Court”) blocked the proposed $54 billion merger between Anthem, Inc. (“Anthem”) and Cigna Corp. (“Cigna”). This ruling comes on the heels of the Court’s decision to block the other insurance mega-merger ($37 billion) between Aetna Inc. and Humana Inc. Anthem has…Read More

On March 20, 2017, the Centers for Medicare & Medicaid Services (“CMS”) published an interim final rule (the “Interim Final Rule“) effectively postponing the start date of CMS’s new episode payment models (“EPMs”) and the Cardiac Rehabilitation Incentive Payment Model (“CR Incentive Model”) from July 1, 2017 until October 1, 2017. The Interim Final Rule…Read More

Background on Title IX On June 23, 1972, President Nixon signed Title IX of the Education Amendments of 1972 into law. Title IX provides that “[n]o person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education…Read More

House Budget Committee Advances American Health Care Act On March 16, the House Budget Committee voted 19-17 to advance the ACA repeal and replace legislation known as the American Health Care Act (“AHCA”). The bill passed despite the opposition of several conservatives on the committee who opposed the measure on the grounds that it doesn’t…Read More