News & Analysis as of

Fees Advisory Opinions

ArentFox Schiff

Telehealth Staffing and Administrative Services Gain Favorable Advisory Opinion From OIG

ArentFox Schiff on

On June 6, the US Department of Health and Human Services’ Office of Inspector General (OIG) issued Advisory Opinion No. 25-03, providing important guidance for telehealth organizations and management services organizations...more

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2024

CFPB Issues Filing Instructions Guide for Small Business Lending Data - The CFPB has published instructions for banks and other covered financial institutions to submit small business lending data that is required to be...more

Hudson Cook, LLP

CFPB Bites of the Month - August 2024 - All That's Left of the CFPB's Summer Sky

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior and current month covered during the August 2024 webinar....more

Venable LLP

A Fall of Fees: CFPB and FTC Announce New Efforts to Fight Alleged “Junk Fees”

Venable LLP on

Large banks and credit unions must provide certain information to customers free of charge, such as account balances, transaction history, and fees, according to an advisory opinion issued by the Consumer Financial Protection...more

Morrison & Foerster LLP

Agencies Take Action on "Junk Fees"

Morrison & Foerster LLP on

On October 11, 2023, the Federal Trade Commission (FTC) issued a proposed rule to prohibit so-called junk fees, and the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion to large banks and credit unions...more

Ballard Spahr LLP

CFPB issues advisory opinion on fees charged by large banks and credit unions to respond to information requests and releases data...

Ballard Spahr LLP on

As we have previously reported on this blog and discussed on our Consumer Finance Monitor Podcast, last year, the CFPB embarked on a campaign orchestrated by the Biden Administration to eliminate “junk fees.” ...more

Hudson Cook, LLP

Indiana Department of Financial Institutions Publishes Advisory Letter on Characterization and Disclosure of E-Lien Fees

Hudson Cook, LLP on

On June 30, 2023, the Indiana Department of Financial Institutions published Advisory Letter 2023-01, addressing the permissibility of e-lien fees not payable to the Indiana Bureau of Motor Vehicles. The publication was...more

ArentFox Schiff

OIG Again Concludes That Online Health Care Provider Marketplace Does Not Violate Fraud and Abuse Laws

ArentFox Schiff on

In Advisory Opinion No. 23-04, the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) analyzed certain proposed changes to the functionality of a health care technology company’s online...more

Hudson Cook, LLP

How Much is Too Much?

Hudson Cook, LLP on

Growing up in New England we both heard that there were three things you should never discuss in public. Politics and religion were two. The third could differ....more

Goodwin

FINRA Requests Comment on Its Machine-Readable Rulebook Initiative

Goodwin on

Regulatory Developments - FINRA Requests Comment on Its Machine-Readable Rulebook Initiative - On October 21, FINRA released a special notice requesting comment on the launch of its MRR initiative. The MRR is designed...more

BCLP

CFPB guidance on pay-to-pay fees impacts consumer loan agreements

BCLP on

Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more

Venable LLP

CFPB Warns Debt Collectors of Illegal Pay-to-Pay Fees

Venable LLP on

The Consumer Finance Protection Bureau ("CFPB") issued an advisory opinion warning debt collectors that they may be collecting illegal fees from consumer-borrowers. Specifically, the Bureau has interpreted Section 808(1) of...more

Venable LLP

Contractual Safeguards That Fall Short of a Safe Harbor

Venable LLP on

According to a recent Advisory Opinion from the Department of Health and Human Services (HHS) Office of Inspector General (OIG), a proposed fee arrangement could run afoul of the Federal anti-kickback statute, 42 USC...more

Mintz - Health Care Viewpoints

OIG Issues Another Favorable Advisory Opinion on Treatment-Based Patient Incentives

The Office of Inspector General for the Department of Health and Human Services (OIG) recently issued another favorable Advisory Opinion on patient incentives (e.g. gift cards or cash equivalents) given as part of patients’...more

Eversheds Sutherland (US) LLP

The DOJ issues its first FCPA advisory opinion after six years of silence

On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more

Baker Donelson

OIG Advisory Opinion 19-04: OIG Approves Health Care Directory's Per-Click Fee Structure

Baker Donelson on

In Advisory Opinion 19-04, published September 10, 2019, the Office of Inspector General (OIG) approved an online health care directory operated on a per-click or per-booking fee arrangement. The proposed directory will be...more

McDermott Will & Emery

CMS Publishes Proposed Amendments to Stark Law Advisory Opinion Regulations

McDermott Will & Emery on

On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) published the CY 2020 Medicare Physician Fee Schedule Proposed Rule, which included substantial changes to the physician self-referral law (Stark Law)...more

Bass, Berry & Sims PLC

Key Takeaways from CMS' New Proposed Rule on Stark Law Advisory Opinions

While the industry awaits more sweeping value-based related changes to the Stark Law regulations, on July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) took a small step toward updating its Stark Law advisory...more

Baker Donelson

OIG Revisits Clinical Laboratory Electronic Data Transmission Fees

Baker Donelson on

Prior Opinion Rescinded and Negative Opinion Issued - The Office of Inspector General (OIG) recently issued a negative advisory opinion about an arrangement that offered relief of a $1 electronic data transmission fee...more

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