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Attention SNFs: Enhanced 855A Disclosure Requirement Deadline Extended to August 1, 2025

This article is an update to a December 2024 client alert. On April 17, 2025, the Centers for Medicare and Medicaid Services ("CMS") extended the revalidation deadline for its 855A skilled nursing facility...more

Attention SNFs: Enhanced 855A Disclosure Requirements Have Arrived

Against the backdrop of increasing regulatory scrutiny of private equity ownership in the healthcare space, Medicare skilled nursing and Medicaid nursing facilities (“SNF”) and private equity companies looking to acquire SNFs...more

CMS Issues Interim Rule in Response to State Medicaid Disenrollment Trend

When the COVID-19 Public Health Emergency (PHE) ended in April 2023, the Families First Coronavirus Response Act’s Medicaid continuous enrollment condition also came to an end. The condition had allowed states to claim a...more

OIG Issues Unfavorable Opinion About Bundling Free Items with Reimbursable Services

On Oct. 25, 2023, the Office of Inspector General (OIG) for the Department of Health and Human Services (DHHS) issued an unfavorable opinion in response to a manufacturer’s proposal to offer and provide a free compatible...more

Medicaid Expansion in North Carolina

North Carolina Governor Roy Cooper announced on September 22, that the state’s $30 billion budget bill will become law and effective on October 1. The budget bill funds the North Carolina Medicaid expansion agreement that was...more

FTC Proposes to Vastly Expand the Health Breach Notification Rule

The Federal Trade Commission (FTC) recently proposed changes to the Health Breach Notification Rule (Rule), enacted in 2009, to clarify that the Rule applies directly to an estimated 170,000 health and wellness mobile...more

End of the Public Health Emergency Marks End of HIPAA Enforcement Discretion for Telehealth Practices

The COVID-19 public health emergency (PHE) in the United States came to an end on May 11, 2023. Simultaneously, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) announced that its enforcement...more

The OIG Provides Stakeholders a Newly Expanded FAQ Process

The Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) published a revamped frequently asked questions (“FAQs”) page and process on March 23, 2023, creating a new platform to...more

HRSA Issues First Round of Final Repayment Notices for Certain Provider Relief Fund Recipients

The Health Resources & Service Administration (“HRSA”) has begun issuing Final Repayment Notices to providers who received Provider Relief Funds (“PRF”) under the following circumstances: Providers who rejected the Terms and...more

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