On October 22, 2019, CMS and OIG (Office of Inspector General) released new proposed rules regarding Stark Law Exceptions and Anti-Kickback Safe Harbors in response to what has universally been christened as the “Regulatory Sprint to Coordinated Care”, first announced by HHS in June of 2018.
As background, please remember that, although the Anti-Kickback Safe
The federal government/Trump administration announced today a delay regarding a proposed rule requiring hospitals to disclose actual negotiated price rates. See WSJ News.
In January, 2019, as reported in the MedLaw Blog on January 10, 2019, CMS added a rule requiring hospitals to publish their standard charges beginning January 2019.
As noted in
On October 23, 2019, the U.S. Department of Health and Human Services, Office for Civil Rights (“HHS”) announced a $2,154,000 civil money penalty for numerous violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security and Breach Notification Rules between 2013 and 2016.
According to HHS, Jackson Health System (“JHS”) is a
HHS has long admitted that the Anti-Kickback Statute (AKS) and the Stark law have not evolved to keep pace with the transition to value based care. In June of 2018, HHS issued an RFI seeking additional information and HHS also issued a release on December 12, 2018 seeking input on improving care coordination and reducing
Click here to read Mike Cassidy’s article which was featured in the Legal Report section of the September 2019 edition of the Allegheny County Medical Society Bulletin.
Mike Cassidy has been honored as one of the Best Lawyers in America for the 11th consecutive year.
The Pennsylvania Commonwealth Court, on remand from the Pennsylvania Supreme Court, has again decided that the previously agreed termination date of the access provisions contained in the UPMC/Highmark Consent Decrees, i.e. June 30, 2019, is not a term subject to the modification provisions of those Consent Decrees, and is definite. The adjudication of the Commonwealth
The Patient Test Result Information Act was effective December 23, 2018.
The Act requires entities performing diagnostic imaging services, defined to include any medical imaging test intended to diagnose the presence or absence of a disease, to provide notice of the results to patients. The operative language states:
“When, in the judgment of the entity
Although there have been a number of issues raised by the Pennsylvania Attorney General in the UPMC/Highmark situation, including UPMC’s status as a charitable institution, the primary issue in the Attorney General’s lawsuit was a request to extend the June 30, 2019 termination date for the UPMC-Highmark Consent Decrees. The Commonwealth Court declined to extend
This article originally appeared in the March edition of the Allegheny County Medical Society Bulletin.