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Civil Monetary Penalty Enforcement Centers for Medicare & Medicaid Services (CMS)

Foley & Lardner LLP

Health Care Enforcement: “Tea Leaves” in the 2024 National Health Care Fraud Summer Takedown

Foley & Lardner LLP on

Each summer in recent years, the U.S. Department of Justice (DOJ) and associated fraud enforcement partners have indicted many health care defendants, in multiple cases across the country. This summer continued the tradition....more

Gardner Law

CMS Audits on the Horizon: Prepare for Increased CMS Audits Under the Sunshine Act

Gardner Law on

Historically, the Centers for Medicare and Medicaid Services (“CMS”) has not aggressively pursued enforcement activity under the Sunshine Act. However, this may change in 2024. Late last year, CMS updated its Open Payments...more

King & Spalding

CMS Issues Interim Final Rule for CMS Enforcement of State Compliance with Reporting and Federal Medicaid Renewal Requirements

King & Spalding on

On December 4, 2023, CMS issued an interim final rule (the Interim Rule) (RIN 0938-AV26) to implement new enforcement authorities that CMS may use if states fail to comply with new reporting requirements or with federal...more

Snell & Wilmer

CMS Revises Enforcement Guidance—Again

Snell & Wilmer on

After the publication of our Legal Alert on the Supreme Court decision lifting the stay on the Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule (the “Rule”) published by the Centers for Medicare & Medicaid...more

Foley Hoag LLP

Details on OSHA, CMS Vaccination Rules Released

Foley Hoag LLP on

On November 6, 2021, the Fifth Circuit Court of Appeals temporarily blocked enforcement of the OSHA vaccination-or-testing rule. Citing “grave statutory and constitutional issues” with the rule, a three-judge panel issued the...more

McDermott Will & Emery

CMS Increase in Mandated Nursing Facility CMPs

McDermott Will & Emery on

The Centers for Medicare & Medicaid Services (CMS) recently published a letter to State Survey Agency Directors describing revisions to Chapter 7 of the State Operations Manual (SOM) to reflect mandatory disciplinary...more

Poyner Spruill LLP

Nursing Facility Survey Trends - Directed Plans of Correction, Privacy Violations and FTag 520 Quality Assurance Committee...

Poyner Spruill LLP on

Directed Plans of Correction, or DPOCs, have long been part of the arsenal of enforcement sanctions available to the Centers for Medicare & Medicaid Services for survey deficiencies, just like civil money penalties (CMPs);...more

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