On April 3, 2020, OIG issued a process for inquiries to be submitted to OIG about the application of administrative enforcement authorities against certain arrangements directly connected to the 2019 novel coronavirus...more
Update: This article was originally published on April 9, 2020. It has been updated to reflect new guidance released on April 10, 2020, by the Department of Health and Human Services (HHS) regarding the delivery of the...more
Update: This article was originally published April 2, 2020. It has been updated to reflect new guidance made available recently in federal responses to the COVID-19 pandemic and summarizes important interactions that...more
On March 31, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule with comment period (IFC). This alert is part of a series of alerts discussing the IFC provisions and comprehensive actions...more
On April 3, 2020, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) issued a policy statement announcing that the OIG will exercise its enforcement discretion not to impose...more
As discussed in a previous alert from March 24, 2020, due to the 2019 novel coronavirus (COVID-19) pandemic, the Centers for Medicare & Medicaid Services (CMS) announced it would temporarily ease quality reporting...more
On March 31, 2020, the Centers for Medicare & Medicaid Services announced temporary measures that will allow ambulatory surgery centers (ASCs) no longer doing elective and non-essential procedures during the COVID-19 outbreak...more
On March 30, 2020, Department of Health and Human Services Secretary Alex Azar issued blanket waivers to permit certain financial relationships and referrals that would otherwise be sanctioned by the Physician Self-Referral...more
On March 30, 2020, Christi A. Grimm, Principal Deputy Inspector General of the Department of Health and Human Services (HHS) Office of Inspector General (OIG), issued a letter to the OIG’s website outlining the OIG’s...more
Due to the novel coronavirus (COVID-19) pandemic, the Centers for Medicare & Medicaid Services (CMS) announced it would temporarily ease quality reporting requirements for clinicians, providers and healthcare facilities...more
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). This is alert is part of a series of alerts discussing the CARES Act provisions that are most important to...more
3/31/2020
/ Business Interruption ,
CARES Act ,
Coronavirus/COVID-19 ,
Financial Stimulus ,
Health Care Providers ,
Healthcare Facilities ,
Hospice ,
Hospitals ,
Relief Measures ,
SBA Lending Programs ,
Telehealth
On March 28, 2020, the Centers for Medicare & Medicaid Services (CMS) released guidance expanding its Accelerated and Advanced Payment Program, which now allows most Medicare Part A and Part B providers and suppliers to...more
As effects from the 2019 novel coronavirus (COVID-19) pandemic set in, stay-at-home orders and business closures are disrupting American lives and businesses. The healthcare industry is no exception, with the pandemic both...more
3/30/2020
/ Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Emergency Management Plans ,
Health Care Providers ,
Medicaid ,
Medical Reimbursement ,
Medicare ,
Public Health ,
Relief Measures ,
Telehealth ,
Telemedicine
As the 2019 novel coronavirus (COVID-19) pandemic continues to strain the healthcare industry, the Centers for Medicare & Medicaid Services (CMS) eased healthcare provider enrollment rules. CMS has significantly streamlined...more
3/30/2020
/ Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Emergency Response ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Medicare ,
OCR ,
Physicians ,
Public Health ,
Relief Measures ,
Telehealth ,
Telemedicine ,
Waivers
All courts agree that litigants asserting attorney-client privilege or work product protection must establish the protection's applicability. But courts take different positions on whether any presumptions guide their...more
As the 2019 novel coronavirus (COVID-19) continues to spread and disrupt American lives and businesses, the healthcare industry will experience significant practical, financial and legal challenges. As federal and local...more
On March 16, 2020, the U.S. House of Representatives unanimously passed corrections to the Families First Coronavirus Response Act (H.R. 6201), which was originally passed by the House on March 14, 2020. On March 19, the...more
On March 14, 2020, the U.S. House of Representatives voted 363 to 40 (with one representative voting present) to pass H.R. 6201 – Families First Coronavirus Response Act. The bipartisan legislation, negotiated between House...more
The DOJ recently announced that Boston Heart Diagnostics Corporation (Boston Heart) has agreed to pay a $26.67 million settlement related to alleged violations of the Federal Anti-Kickback Statute and the Stark Law. This...more
The Deputy General Counsel and Chief Legal Officers at the U.S. Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) recently issued an Internal Memorandum clarifying that a recent...more
As discussed in an Oct. 9 alert, the Department of Health and Human Services announced two proposed rules to significantly amend the Physician Self-Referral Law (Stark Law), the federal Anti-Kickback Statute and the Civil...more
As discussed in a previous McGuireWoods alert, on Oct. 9, the Department of Health and Human Services announced two proposed rules to significantly amend the Physician Self-Referral Law (Stark Law), the federal Anti-Kickback...more
As discussed in a previous McGuireWoods alert, on Oct. 9, the Department of Health and Human Services (HHS) announced two proposed rules to significantly amend the Physician Self-Referral Law (Stark Law), the federal...more
On Oct. 9, the Department of Health and Human Services announced two proposed rules to significantly amend the Physician Self-Referral Law (Stark Law), the federal Anti-Kickback Statute (AKS) and the Civil Monetary Penalties...more
On Sept. 17, 2019, a Washington, D.C. district court judge ruled that the Centers for Medicare & Medicaid Services (CMS) “exceeded its statutory authority when it cut the payment rate for clinic services at off-campus...more