Articles and Blogs

Executive Summary On September 9, 2015, Deputy Attorney General Sally Quillian Yates of the Department of Justice (“DOJ”) issued to various divisions within the DOJ and released to the public a Memorandum addressing individual accountability for corporate wrongdoing.  This Memo is the latest in a long-running series of DOJ memorandums addressing corporate misconduct. 

House Speaker John Boehner Announces Retirement from Congress In a meeting with House Republicans early September 25, Speaker John Boehner (R-OH) announced that he will give up the speakership and resign his seat in Congress effective at the end of October.  The move comes in the midst of a contentious debate between Boehner and House…Read More

Background Employers continue to await information regarding the effect of the Department of Labor’s (“DOL’s”) proposed changes to the companionship services exemption under the Fair Labor Standards Act.  As previously reported, the DOL issued a new rule significantly changing the scope of the companionship services exemption.  Though the new rule was scheduled to take effect…Read More

Background On September 8, 2015, the Department of Health and Human Services (“HHS”), through the Office for Human Research and Protection (“OHRP”), proposed several significant changes to the Federal Policy for the Protection of Human Subjects (the “Common Rule”).  In its notice of proposed rulemaking (“NPRM”), HHS and 15 other federal agencies and departments announced…Read More

According to a recent study by the British Medical Journal (“BMJ”) titled Access, Quality, and Costs of Care at Physician Owned Hospitals in the United States: Observational Study (“Study”), physician-owned hospitals (“POHs”) generally do not treat a higher volume of the most profitable patients (commonly referred to as “cherry-picking”) than other hospitals1.  The Study disputes…Read More

House Ways and Means Committee Moves Health Care-Related Bills On September 17, the House Ways and Means Committee marked up group bills, including health care-related legislation that would expand the religious liberty exemption to the individual mandate. The second bill would allow individuals to use health savings accounts (“HSAs”) and similar vehicles to use those…Read More

President Obama signed a new Executive Order on September 7, 2015 that will require certain federal contractors to provide employees up to 56 hours of paid sick leave per year.  The leave can be used for the employee’s care or if the employee needs to take care of a family member.  The new obligations are…Read More

HRSA Issues Omnibus 340B Guidance On August 27, the Health Resources and Services Administration (“HRSA”) issued omnibus guidance on the 340B Drug Discount Program via the Federal Register. The proposed guidance would clarify the definition of a 340B patient, contract pharmacy arrangements, audit procedures and other related provisions.  Earlier this year, the House Energy and…Read More

Executive Summary As part of the Immigration Accountability Executive Action issued by President Obama on November 20, 2014 (detailed here), United States Citizenship and Immigration Services (“USCIS”) and the Department of State (“DOS”) announced revised procedures yesterday in determining visa availability for applicants waiting to file for adjustment of status.  The new procedures are intended to more accurately estimate…Read More

Executive Summary On August 28, 2015, the Health Resources and Services Administration (“HRSA”) released its long-awaited proposed 340B Drug Pricing Program Omnibus Guidance.  The notice (a copy of which can be found here) proposes to establish guidance addressing a variety of longstanding open questions for covered entities enrolled in, and drug manufacturers participating in, the…Read More