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Health Care

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…

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…

The Supreme Court Endorses "Implied Certification"

Hospitals which have discovered violations in their submissions for payment under Medicare and Medicaid may now pause before reporting the mistake and determine if the violation was “material” to the government’s conditions for payment. If the…