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Health Care

OIG Post New Advisory Opinion on Laboratory Services

On December 5, 2016, the OIG posted Advisory Opinion No. 16-12 concerning a laboratory’s proposal to provide the labeling of test tubes and specimens free of charge to dialysis facilities.  One of the stated purposes of offering this free service was to “obtain or retain the business of a particular…

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CMS Finalizes Emergency Preparedness Rule for Health Care Facilities

On September 8, 2016, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Emergency Preparedness Rule (Final Rule”) for health care facilities.  CMS has given significant attention to the Final Rule in light of the many major disasters that have occurred in the last ten years and…

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Key Features of Medicare Access & CHIP Reauthorization Act of 2015

Medicare Access & CHIP Reauthorization Act of 20151

On April 27, 2016, the Centers for Medicare and Medicaid Services (“CMS”) issued a Notice of Proposed Rulemaking to implement parts of the Medicare Access & CHIP Reauthorization Act of 2015 (“MACRA”). MACRA is part of an initiative…

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Six States and Various Religious Organizations File Suit to Invalidate the New Office of Civil Rights Anti-Discrimination Regulations

The Franciscan Alliance and Christian & Medical Dental Associations joined six states in a lawsuit filed against Health and Human Services (“HHS”) in a Texas federal court on August 23, 2016, challenging the regulations that the HHS’ Office of Civil Rights (“OCR”) finalized this past May (“Final…

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HHS Office of Civil Rights Publishes Final Regulations Prohibiting Discrimination in Health Care Programs and Activities Receiving Federal Financial Assistance

The Health and Human Services’ Office of Civil Rights (“OCR”) recently published a final Regulation (“Regulation”) that implements the nondiscrimination requirements of Section 1557 of the Patient Protection and Affordable Care Act.[1]  Beginning on July 18, 2016, discrimination in health care…

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The Yates Memo and Warner Chilcott – Fallout from the Trial

Following up on a previous client alert item, a federal jury recently found W. Carl Reichel, former president of Warner Chilcott, not guilty on June 17, 2016 of conspiring to pay kickbacks to doctors in exchange for writing prescriptions. The jury deliberated two days before delivering a not guilty…

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