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CMS’s Rescission of 2022 EMTALA Guidance Presents New Considerations for Hospitals, Post-Dobbs

The Centers for Medicare & Medicaid Services (CMS) recently rescinded its July 2022 guidance titled “Reinforcement of EMTALA Obligations specific to Patients who are Pregnant or are Experiencing Pregnancy Loss” (“2022...more

Interested in Opening a Medical Spa? (Part II): Here’s (More) That You Need to Know

In April, we shared with you our thoughts on what to consider before opening in or investing in a medical spa, thinking about corporate structure, scope of practice, licenses and registrations, referral restrictions, HIPAA...more

CMS Announces the Making Care Primary Model, a Multistate Initiative to Strengthen Primary Care

On June 8, 2023, the Centers for Medicare & Medicaid Services (CMS), Center for Medicare and Medicaid Innovation (CMMI), announced a new demonstration model under the authority of Section 1115A of the Social Security Act that...more

In Wake of Dobbs Decision, CMS Issues Guidance to Hospitals on EMTALA Obligations

Last week, the Centers for Medicare & Medicaid (CMS) issued guidance to remind hospitals of their ongoing federal obligations under the Emergency Medical Treatment and Labor Act (EMTALA), specifically when treating patients...more

OIG Issues Favorable Advisory Opinion on Ambulatory Surgery Center Joint Venture

The U.S. Department of Health and Human Services’ Office of Inspector General (“OIG”) recently issued Advisory Opinion No. 21-02, regarding a joint investment by a health system, a manager, and certain surgeons in an...more

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