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While You Were Sleeping: HHS Releases New Guidance on Sensitive Examinations

"Informed consent" has been described as "a bedrock principle of healthcare in a free society," and if a "patient is denied the ability to exercise or even consider informed consent, the patient's personal liberty suffers."1...more

Court Upholds OIG Advisory Opinion Shooting Down a Patient Assistance Program

Healthcare compliance risks exist even when a company takes steps to structure its business activities to follow the government's own statements. A recent decision by the U.S. District Court for the Eastern District of...more

EMTALA Patient Education Initiative Launched by HHS and CMS

The U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) have started a new effort to educate the public about the Emergency Medical Treatment and Labor Act (EMTALA)....more

Healthcare Law Update: February 2020

Neurosurgeons' Compensation in Top 10 Percent Nationwide Gives Rise to Stark Act and FCA Claims - In United States ex re. Bookwalter v. UPMC, 946 F. 3d 162 (3d Cir. 2019), the court ruled that the relators stated a Stark...more

Hospitals Sharing Space – CMS Draft Guidance for Co-Location

As new healthcare delivery models evolve, we may see an increase in hospitals that share space with other hospitals or healthcare entities. On May 3, 2019, Centers for Medicare and Medicaid Services (CMS) issued draft...more

CMS Clarifies Immediate Jeopardy Guidance

When a surveyor cites "immediate jeopardy" at a provider, supplier or laboratory’s location it can lead to serious consequences, including potential fines and termination from federal healthcare programs. On March 5, 2019,...more

CMS Memo on Texting Patient Information

CMS issued a memo to state survey agency directors on December 28, 2017, to clarify CMS’s position on texting patient information. The memo, which indicates that it is effective “immediately,” states that CMS prohibits...more

OIG Reports That CMS Has Inadequate System for Identifying SNF Abuse

The U.S. Department of Health & Human Services Office of Inspector General (OIG) has issued an “Early Alert” regarding the preliminary results of an ongoing study of potential abuse or neglect in Medicare-certified skilled...more

New OIG Special Fraud Alert Focuses on Suspect Practices of Labs and Referring Physicians - Certain Payment Arrangements May Be a...

The U.S. Department of Health and Human Services' Office of Inspector General (OIG) issued a new Special Fraud Alert on June 25, 2014, that focuses on certain compensation arrangements between laboratories and referring...more

The New "Meaningful Use" Landscape: A Transition from Incentives to Penalties - CMS Begins Enforcing Penalties for Failure to...

Starting in 2015, eligible physicians and hospitals participating in the Medicare Electronic Health Records Incentive Program who do not adopt "meaningful" use" certified electronic health record (EHR) technology will no...more

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