The US Department of Health and Human Services (HHS) and the US Department of Justice (DOJ) recently published new proposed rules that update and create various requirements under Section 504 of the Rehabilitation Act of 1973...more
The Illinois attorney general (IL AG) has released its much-anticipated Healthcare Transaction Notice Form (the Form), which parties must submit before undertaking certain “Covered Transactions” that are not otherwise...more
On November 6, 2023, the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) published the General Compliance Program Guidance (GCPG) as a revised reference guide for the healthcare compliance...more
11/16/2023
/ Anti-Kickback Statute ,
Compliance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Food and Drug Administration (FDA) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Healthcare Fraud ,
OIG ,
Patients ,
Stark Law
On August 11, 2023, Governor J. B. Pritzker signed Illinois House Bill 2222 into law (Public Act 103-0526). Public Act 103-0526 amends certain provisions of the Illinois Antitrust Act, the State Finance Act and the Illinois...more
8/17/2023
/ Antitrust Division ,
Covered Transactions ,
Enforcement ,
General Assembly ,
Governor Pritzker ,
Hart-Scott-Rodino Act ,
Health Care Providers ,
Healthcare ,
Healthcare Facilities ,
New Legislation ,
State Attorneys General ,
State Legislatures
The Centers for Medicare and Medicaid Services (CMS) published an interim final rule with comment period (IFR) on November 5, 2021, that implements the Biden administration’s previously announced vaccine mandate for...more
[co-authors: Timothy Cotter and Kathryn Hastings, SullivanCotter; David Jarrard, Jarrard Inc.; Ken Kaufman and Andrew Majka, KaufmanHall; Zachary Morfin, PhD., and David Nygren, PhD., Nygren Consulting; Scott Steffens, Grant...more
10/13/2021
/ Audit Committee ,
Board of Directors ,
Compensation Committee ,
Corporate Communications ,
Corporate Governance ,
Corporate Management ,
Corporate Social Responsibility ,
Corporate Strategy ,
Diversity and Inclusion Standards (D&I) ,
Employee Engagement ,
Executive Compensation ,
Health Care Providers ,
Healthcare ,
Human Capital ,
Privacy Committee ,
Shareholders
The application of EMTALA to psychiatric hospitals has long presented compliance concerns for psychiatric hospital providers. To provide clarity, the CMS recently released two memos that offer incremental additional guidance....more
7/8/2019
/ Centers for Medicare & Medicaid Services (CMS) ,
EMTALA ,
Health and Safety ,
Health Care Providers ,
Healthcare ,
Hospitals ,
New Guidance ,
OCR ,
Patient Rights ,
Patient Safety ,
Psychiatric Hospitals
On October 28, 2015, the U.S. House of Representatives approved legislation that, if enacted, would, among other things, substantially alter how and how much Medicare pays for outpatient services furnished by hospitals. The...more
10/30/2015
/ Ambulatory Surgery Centers ,
Centers for Medicare & Medicaid Services (CMS) ,
Debt Ceiling ,
Federal Budget ,
Generic Drugs ,
Health Care Providers ,
Healthcare ,
Hospitals ,
HRSA ,
Medicaid ,
Medicare ,
Medicare Part B ,
OPPS ,
Pending Legislation ,
Physician Fee Schedule ,
Physicians ,
Prescription Drugs ,
Rebates ,
Section 340B ,
Sequestration
On July 13, 2015, the Centers for Medicare & Medicaid (CMS) issued a long-awaited proposed rule (Proposed Rule) that would revise the requirements that long-term care (LTC) facilities must meet to participate in the Medicare...more
7/16/2015
/ Affordable Care Act ,
Binding Arbitration ,
Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Elder Abuse ,
Employee Training ,
Federal Register ,
Health Care Providers ,
Healthcare ,
Healthcare Reform ,
Long Term Care Facilities ,
Long-Term Care ,
Medicaid ,
Medicare ,
Neglect ,
Nurse Practitioners ,
Nurses ,
Physicians ,
Prescription Drugs ,
Proposed Regulation ,
Quality Assurance Programs ,
Training Requirements
The onset of active Ebola infections in the U.S. places hospitals and health care facilities in somewhat “uncharted waters” regarding their respective legal risks related to clinical care and the clinicians providing that...more
On May 7, 2014, the U.S. Centers for Medicare & Medicaid Services (CMS) issued a long-awaited final rule in response to President Obama’s Executive Order (EO) 13563, “Improving Regulation and Regulatory Review,” which set as...more
5/14/2014
/ Barack Obama ,
Centers for Medicare & Medicaid Services (CMS) ,
Executive Orders ,
Final Rules ,
Health Care Providers ,
Healthcare ,
Healthcare Costs ,
Healthcare Facilities ,
Hospitals ,
Medicaid ,
Medicare
Hospitals gearing up for implementation of the “2 Midnights Rule” have more time to prepare—or consider joining efforts to modify or rescind the rule—now that CMS has delayed implementation for a third time....more
The Centers for Medicare & Medicaid Services (CMS) recently announced revisions to its State Operations Manual that change the complaint survey investigation process and typical timeline for resolution....more