The Federal Corporate Transparency Act (the CTA), 31 U.S.C. ยง5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...more
12/8/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Centers for Medicare & Medicaid Services (CMS) ,
Corporate Transparency Act ,
Covered Entities ,
Disclosure Requirements ,
Exemptions ,
Filing Deadlines ,
Financial Crimes ,
FinCEN ,
Foreign Entities ,
Health Care Providers ,
Healthcare Facilities ,
Medicaid ,
Medicare ,
National Security ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
This August, a working group sponsored by the National Association of Insurance Commissioners (the "NAIC") unanimously approved revisions to the NAIC's Unfair Trade Practices Act Model #880 (the "Model Law") to restrain...more
9/20/2023
/ Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
False Marking ,
Health Insurance ,
Insurance Industry ,
Lead Generators ,
Marketing ,
Medicaid ,
Medicare ,
NAIC ,
Open Enrollment ,
The Model Law ,
Unfair or Deceptive Trade Practices ,
Working Groups
On June 1, 2023, the U.S. Supreme Court issued a unanimous opinion in United States ex rel. Schutte v. SuperValu Inc. reversing a pair of False Claims Act (FCA) cases on review from the Seventh Circuit Court of Appeals. In...more
6/7/2023
/ Drug Pricing ,
False Claims Act (FCA) ,
Fraud ,
Medicaid ,
Medicare ,
Objective Falsity ,
Objective Standard ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Qui Tam ,
Reasonable Interpretations ,
Scienter ,
SCOTUS ,
Subjective Standard ,
Universal Health Services Inc v United States ex rel Escobar ,
US ex rel Thomas Proctor v Safeway Inc ,
US ex rel Tracy Schutte et al v SuperValu Inc et al
In January 2020, Alex M. Azar, II, then secretary of the U.S. Department of Health and Human Services (HHS), signed a nationwide declaration of a Public Health Emergency (PHE) that would largely shape the response of public...more
12/1/2022
/ Advance Notice ,
Children's Health Insurance Program (CHIP) ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Infectious Diseases ,
Medicaid ,
Medicare ,
Notice Requirements ,
Public Health Emergency ,
Secretary of HHS ,
Social Security Act ,
Waivers