In October of 2019, the Centers for Medicare and Medicaid Services (“CMS”) and the Office of Inspector General, U.S. Department of Health and Human Services (“OIG”) issued proposed rule changes to the Stark and federal Anti-Kickback Statute (“AKS”), respectively, that put forth many helpful updates intended to encourage and advance […]
Health Law Alert
The Revised Rule on the Confidentiality of Substance Use Disorder Records (For Now)
on Thursday, 6 August 2020 in
Health Law Alert: Erin E. Busch, Editor
In July, the Substance Abuse and Mental Health Services Administration (“SAMHSA”) published an update to 42 CFR Part 2, better known simply as “Part 2.” This rule, as part of the “Regulatory Sprint to Coordinated Care,” finalizes certain changes proposed last year. These changes should not be overlooked by the […]
IRS Issues Proposed Excess Compensation and Parachute Payment Rules
on Thursday, 6 August 2020 in
Health Law Alert: Erin E. Busch, Editor
On June 5, 2020, the Internal Revenue Service (“IRS”) issued proposed rules under Section 4960 of the Internal Revenue Code (the “Code”), as added by the Tax Cuts and Jobs Act (Pub. L. 115-97). While there may be significant press about these rules, the good news is that they will […]
American Hospital Association v. Azar: Upholding CMS’s Final Rule on Price Transparency for Hospitals
on Thursday, 6 August 2020 in
Health Law Alert: Erin E. Busch, Editor
On June 23, 2020 the U.S. District Court for the District of Columbia upheld a final rule requiring hospitals to publicly post “standard charges” on the internet in Am. Hospital Assoc. v. Azar, No. 1:19-cv-03619 (D.D.C. June 23, 2020). The Centers for Medicare and Medicaid Services’ (“CMS”) final rule on […]
OFCCP Exempts TRICARE Participants from Affirmative Action Obligations
on Tuesday, 7 July 2020 in
Health Law Alert: Erin E. Busch, Editor
Finally, some good news in 2020! On Thursday, July 2, 2020, the Office of Federal Contract Compliance Programs (“OFCCP”), published its final rule explicitly exempting certain health care providers from the OFCCP’s enforcement activities as they relate to affirmative action. Specifically, the final rule exempts TRICARE health care providers from […]
