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Insights

HIPAA Business Associates ... How Do I Know Thee?

HIPAA, as amended by HITECH, imposes significant requirements on those persons or entities who qualify as a business associate (BA) as a result of their access to protected health information (PHI) in the performance of services on behalf of a…

Puzder out, Acosta In as Secretary of Labor Pick

Just a day after CKE Restaurants CEO Andy Puzder, amid allegations of conflicts of interest and possible discontent among employees, withdrew his nomination to serve as Secretary of Labor, President Trump has tabbed R. Alexander Acosta to head the…

Preparing Your Facility for the MOON

On January 27, 2017, CMS issued final guidance regarding implementation of its Medicare Outpatient Observation Notice (MOON) program. The MOON informs all Medicare beneficiaries (both traditional fee-for-service and Medicare Advantage) when they are…

CMS "Mid-Build" Exception Deadline and Provider-Based Growth Strategies

The Bipartisan Budget Act of 2015 (“Section 603”) made waste of many hospitals’ plans for off-campus provider-based practice locations. Notwithstanding, a final reprieve for certain provider-based facilities is the 21st Century Cures Act’s…