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... 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... 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,... 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... 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... READ MORE

Tuesday, March 31 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, FEMA Create Supply Chain Task Force HHS and the Federal Emergency... READ MORE

On March 30, 2020, OIG released a message to health care providers reinforcing OIG’s continued focus on aggressively pursuing bad actors exploiting the COVID-19 crisis but also praising the hard work and dedication of the frontline providers who are serving heroically in this crisis. This is in follow-up to our previous COVID-19-related guidance pertaining... READ MORE

The Telephone Consumer Protection Act (“TCPA”) generally prohibits the use of automated text messages or prerecorded calls to a cellular number without the prior consent of the receiving party. The TCPA expressly excepts from the foregoing prohibition any calls or messages sent for “emergency purposes.” See 47 C.F.R. § 64.1200(f)(4). In a Declaratory Ruling... READ MORE

On March 30, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued blanket waivers of several Stark Law requirements related to COVID-19 physician arrangements. These waivers are welcome news to hospitals, health systems and other providers that have been tackling challenging physician contracting, compensation and staffing issues over the past month. Timeframe The... READ MORE

On March 23, 2020, Centers for Medicare & Medicaid Services (“CMS”) announced the preliminary results of a recent survey of a nursing home in Kirkland, Washington, the epicenter of the COVID-19 outbreak in Washington. According to a Centers for Disease Control and Prevention (“CDC”) report, 81 residents, 34 staff and 14 visitors also became... READ MORE