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Compliance Update: RCRA 'Subpart P' and the New Hazardous Waste Pharmaceutical Rules

Posted by: Matthew D. Neumann on August 9, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

Health care facilities will need to comply with new regulations governing the management and disposal of Hazardous Waste Pharmaceuticals (“HWPs”). The Environmental Protection Agency (“EPA”) has promulgated new rules to be codified at 40 C.F.R. Part 266, Subpart P of the implementing regulations...


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CMS Issues Long Awaited Clarification on Application of EMTALA to Psychiatric Hospitals

Posted by: Meghan M. Linvill McNab and Amanda K. Schipp on August 6, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

On July 2, 2019, the Centers for Medicare and Medicaid Services (“CMS”) issued a letter to State Survey Agency Directors with Frequently Asked Questions on the application of the Emergency Medical Treatment and Labor Act (“EMTALA”) to Psychiatric Hospitals (the “FAQ”).  This is the second time...


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Department of Justice Publishes New Guidance for Evaluating Corporate Compliance Programs

Posted by: Susan E. Ziel and Brandon W. Shirley on August 6, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

On April 30, 2019, the United States Department of Justice (“DOJ”) published new recent guidance for corporate compliance programs, entitled “Evaluation of Corporate Compliance Programs.” Such publications are particularly helpful as they provide guidance for white-collar prosecutors on the...


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Say What You Mean and Mean What You Say - Especially to the Feds

Posted by: Robert A. Anderson and Marc T. Quigley on July 23, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The recent settlement between Coffey Health System in Kansas and the U.S. government is a cautionary tale to other healthcare providers: false attestations related to government incentive programs could lead to False Claims Act liability.

Coffey Health System operates a 25-bed critical access...


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Indiana Medicaid Modifies Coverage of Certain Mental Health Services

Posted by: Meghan M. Linvill McNab and Amanda K. Schipp on July 23, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

On May 30, 2019, the Indiana Health Coverage Programs (“IHCP”) released a bulletin (BT201929) stating that it is modifying coverage of crisis intervention, intensive outpatient treatment (“IOT”) and peer recovery services for Indiana Medicaid, effective July 1, 2019.  The two notable changes are...


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Changes to Indiana Physical Therapy Practice Act Provide Greater Authority to Physical Therapists

Posted by: Stacy Walton Long and Alexandria M. Foster on July 2, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The Indiana General Assembly recently passed legislation (“SB 586”), related to the regulation of physical therapists (“PTs”). Health care providers who utilize physical therapists should be aware of the administrative, licensing, and scope of practice changes included in SB 586. These...


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NPDB Insights and Proctoring Arrangements

Posted by: Susan E. Ziel and Stacy Walton Long on June 28, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

Various healthcare providers use the National Practitioner Data Bank (NPDB) in connection with credentialing medical staff and reporting adverse corrective actions involving professional competence or conduct of practitioners.  

On a monthly basis, NPDB publishes an online report – NPDB...


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