On June 11, 2025, the Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion No. 25-03 (Opinion), which provided favorable guidance for physician practices seeking to contract with...more
The use of technology in healthcare services and payment for healthcare is evolving at an unprecedented pace, reshaping how medical services are delivered, managed, and paid for. The use of artificial intelligence systems...more
3/25/2024
/ Algorithms ,
Anti-Discrimination Policies ,
Artificial Intelligence ,
Bias ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Consent ,
Final Rules ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Medicare ,
Medicare Advantage ,
Medicare Advantage Organizations (MAOs) ,
PHI ,
Software
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 July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) announced a proposal to significantly expand behavioral health coverage provided under Medicare. The proposal, presented as a part of the calendar year 2024...more
8/9/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Drug Treatment ,
Health Care Providers ,
Medicare ,
Mental Health ,
Outpatient Services ,
Physician Fee Schedule ,
Prescription Drugs ,
Proposed Rules ,
Substance Abuse
On July 10, 2023, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule (Proposed Rule) that would (i) include hospices in the 36-month rule ownership transfer restrictions that currently exist for home...more
7/28/2023
/ Accreditation ,
Centers for Medicare & Medicaid Services (CMS) ,
Change of Ownership ,
Dispute Resolution ,
Elder Abuse ,
Elder Issues ,
Fraud ,
Fraud Abuse and Waste ,
Fraud and Abuse ,
Home Health Agencies ,
Hospice ,
MACs ,
Medicare ,
Proposed Regulation ,
Prospective Payment System (PPS) ,
Regulatory Agenda ,
Regulatory Reform ,
Screening Procedures ,
Transfer Restrictions
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
On June 6, 2022, the U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG), released its spring 2022 semiannual report to Congress. The semiannual report covers the period of October 1, 2021 to...more
7/28/2022
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Drug Treatment ,
Durable Medical Equipment ,
Fraud ,
Genetic Testing ,
Health Care Providers ,
Healthcare Fraud ,
Information Reports ,
Medicare ,
OIG ,
Opioid