Articles and Blogs

On February 7, 2013, the United States Health Resources and Services Administration (“HRSA”) released guidance entitled “Statutory Prohibition on Group Purchasing Organization Participation” (“GPO Exclusion Guidance”).  This guidance addresses requirements related to drugs purchased at a discount under the 340B Program by hospitals subject to the 340B Program GPO exclusion restriction.  These include disproportionate share…Read More

The final rule for Stage 2 of Meaningful Use (“MU”) included an outline of the timeline for reviewing and publishing updates to the Clinical Quality Measure (“CQM”) specifications used in the EHR Incentive Program with the determination that the specifications should be updated more frequently than the rulemaking cycle for the Medicare and Medicaid EHR…Read More

ONC is seeking comments on how ONC and CMS policies could result in routine exchange of patient clinical data across care settings.  The deadline to submit comments is April 22, 2013. Click here for more information and procedures for comment submission. Should you have questions, please contact Alisa Kuehn at akuehn@hallrender.com or (317) 977-1475.

The ONC has made available on its website (healthit.gov) a variety of resources to assist those working toward Meaningful Use.  Below are links to a few of these resources: Click here for information on attestation, tipsheets, FAQs, tools and regulations related to Meaningful Use Stage 2. Click here to access the 2014 Edition Test Method…Read More

Executive Summary In Masri v. LIRC, 2012AP1047 (April 2, 2013), the Wisconsin Court of Appeals affirmed a decision by the Labor and Industry Review Commission (“LIRC”) that Wisconsin’s Health Care Worker Protection Act (“HCWPA”) applies only to employees of health care facilities and that an unpaid intern is not an employee for purposes of the…Read More

Proposed Reporting Rule for Charity Hospitals Released On April 3, the Internal Revenue Service and Department of Treasury published a proposed rule on the health care law’s community health needs assessment requirements for charitable hospitals, related excise tax and reporting requirements, and the consequences for failing to complete them.

On Wednesday, April 3, the Internal Revenue Service (“IRS”) released a new round of Proposed Regulations that expand upon, and address uncertainties regarding, the requirements of Code Section 501(r) applicable to tax-exempt hospital organizations. These new Proposed Regulations provide guidance on the community health needs assessment requirements and related excise tax and reporting obligations. Notably,…Read More

OFCCP continued its courtesy of providing advance notice to companies it plans to schedule for affirmative action compliance reviews.  OFCCP mailed the notices, known as Corporate Scheduling Announcement Letters (“CSALs”), on March 27, 2013.  Consistent with its recent practice, the notices are addressed to the “Human Resource Director” at local establishments as opposed to the…Read More

Often times when an employee is at home while on an approved FMLA leave, work-related questions will arise that only the employee can answer.  So, the manager or a co-worker will call the employee at home and get the answer.  Usually that’s not a problem – but it could be depending on how often the…Read More

By Drew B. Howk In U.S. v. Anchor Mortgage Corp., the Seventh Circuit held that treble damage calculations under the FCA must be calculated from the net losses, rather than the gross losses, suffered by the Government. For defendants in FCA litigation, this decision not only affects the potential damages for an adverse judgment but also the relative…Read More