Articles and Blogs

This article is Part II in a five-part series of articles discussing the recently published federal Physician Payment Sunshine Act (“Sunshine Act”).  This article focuses on issues specific to group purchasing organizations and physician investment in health product manufacturers.  The first article in the series provided an overview of the major sections of the Sunshine…Read More

The Centers for Medicare & Medicaid Services (“CMS”), in the March 8, 2013 Memorandum, issued new guidance specifying those tasks that can and cannot be delegated in skilled nursing facilities (“SNFs”) and nursing facilities (“NFs”).  Physicians who improperly assign tasks to non-physician practitioners (“NPPs”) jeopardize the SNFs’ and NFs’ compliance with federal and state regulations,…Read More

NLRB to Petition for Supreme Court Review of Recess Appointments The National Labor Relations Board today announced that it has determined not to seek en banc rehearing in Noel Canning v. NLRB, in which the U.S. Court of Appeals for the D.C. Circuit held that the January 4, 2012 recess appointments of three members to…Read More

The Centers for Medicare & Medicaid Services, in the March 8, 2013 S & C 13-16 NH, revised the Interpretative Guidelines for F-Tag 155 (“Advance Directives”) in Appendix PP of the State Operations Manual.  This memorandum updates S & C 12-47.

According to the Centers for Medicare & Medicaid Services (“CMS”), since 1972, there have been in excess of 100 reports of Luer misconnections that have resulted in adverse events.  Recently, a patient’s blood pressure tubing was misconnected to an intravenous line in an ambulatory surgical center (“ASC”) that resulted in the patient’s death.  Generally, the…Read More

Based on additional feedback, the Centers for Medicare & Medicaid Services (CMS) has revised the surveyor guidance issued in September 2012 on Naso-Gastric Tubes (NG Tubes) for F-Tag F322.  Since the NG Tube regulation, §483.25(g), was published, the use of NG Tubes has become increasingly rare in favor of other forms of enteral feeding tubes….Read More

On March 8, 2013, U.S. Citizenship and Immigration Services (“USCIS”) released the long-awaited new Form I-9 for employers.  The new form is available here and features a newly-designed layout, more detailed instructions and additional data fields for completion.  Employers should begin using the new form immediately. Here is what’s new:

On Friday, March 8, 2013, the Internal Revenue Service (“IRS”) released Form 14429, Tax Exempt Bonds Voluntary Closing Agreement Program Request. The new form is required for a Tax Exempt Bonds Voluntary Closing Agreement Program (“VCAP”) submission request. VCAP provides remedies for issuers of tax-advantaged bonds (e.g., 501(c)(3) tax-exempt bonds) who voluntarily come forward to…Read More

A new Form I-9 was issued by USCIS yesterday, March 8, 2013.  The newly revised Form I-9 includes additional data fields, improved instructions and a new layout that expands the form to two pages.  Employers should begin using the new Form I-9 now.  However, there will be a 60-day grace period until May 7, 2013, during…Read More

House Passes Bill to Fund Government Past March 27 On March 6, the House passed a six-month spending bill to keep the government operating past March 27.  The 267-151 vote sends the measure to the Senate where a bipartisan coalition hopes to expand on the package next week and give Cabinet departments flexibility to cope…Read More