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Health Care / Health Reform Connect®

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CMS Rule Reducing Medicare Payments for Certain Clinic Visits by Off-Campus PBDs

Posted by: Meghan M. Linvill McNab and Brandon W. Shirley on December 13, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The Bipartisan Budget Act (“BBA”) of 2015, and its implementing regulations at 42 CFR 419.22(v) and 419.48 resulted in the movement of payments for nonexcepted provider-based departments (“PBD”) from the outpatient prospective payment system (“OPPS”) to the Medicare Part B site-specific...


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US Department of Justice Announces Changes to Corporate Investigation Protocol

Posted by: Marc T. Quigley and Brandon W. Shirley on December 13, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

U.S. Deputy Attorney General Rod Rosenstein recently announced changes to criminal and civil corporate investigation protocol during a speech on November 29, 2018. For the past several years, the US Department of Justice (“DOJ”) has attempted to adhere to the Yates Memo, which focused on...


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Important Organizational Safeguards to Manage Healthcare Business Relationships

Posted by: Susan E. Ziel and Thomas N. Hutchinson on December 4, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

Since 2003, the Department of Health and Human Services’ Office of Inspector General (“OIG”), often partnering with other healthcare related organizations such as the American Health Lawyers’ Association and the Health Care Compliance Association, have authored a series of publications for...


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We May Finally Know Whether Being a Tricare Provider Makes One a Federal Contractor

Posted by: Amy J. Adolay and Brandon W. Shirley on December 4, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The U.S. Department of Labor (DOL) recently announced plans to clarify application of federal anti-discrimination requirements on health care providers with Tricare enrollment agreements. The DOL and Tricare providers have long been at odds over whether a Tricare enrollment agreement made one a...


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NPDB Guidebook Changes

Posted by: Brian M. Heaton and Meghan M. Linvill McNab on December 4, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The US Department of Health & Human Services updated the National Practitioner Data Bank (“NPDB”) Guidebook, effective October 2018.  The last time the Guidebook was revised was April 2015.  While the 2015 revision included substantial updates to the regulatory scope, content and display of...


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Proposed Regulations Allowing for Expanded Usage of Health Reimbursement Arrangements (HRAs) - Another Step In President Trump's Focus on Health Care Reform

Posted by: Tiffany A. (Sharpley) Hofmeister on November 19, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

A trifecta federal agency approach to expansion efforts related to health reimbursement arrangements (“HRAs”) occurred on October 29, 2018. The Departments of Treasury, Health and Human Services, and Labor (collectively, the “Departments”) jointly announced proposed HRA regulations, effective...


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HIPAA Business Associates … How Do I Know Thee?

Posted by: Susan E. Ziel and Robert A. Anderson on November 19, 2018

Court Decision Clears Way for Broader Use of Postnuptial Agreements

HIPAA, as amended by HITECH, imposes significant requirements on those persons or entities who constitute a business associate as a result of their access to protected health information in the performance of services on behalf of a covered entity.[1] 

For example, a business associate could...


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