Section 501(r) of the Code established a number of requirements for tax-exempt hospitals, including provisions related to financial assistance policies, limitations on charges, and billing and collection matters. Every § 501(c)(3) tax-exempt hospital, including “dual status” governmental hospitals (those governmental hospitals that separately obtained § 501(c)(3) status), must adopt and […]
Health Law Alert
NoMoreClipboard Settles HIPAA Claim with OCR – But Wait! There’s More
Medical Informatics Engineering, Inc., the parent company of NoMoreClipboard, recently paid $100,000 to the U.S. Department of Health and Human Services, Office for Civil Rights (OCR), and entered into a corrective action plan to settle potential violations of the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security Rules. […]
“Cooperation Credit” in False Claims Act Settlements
On May 6, 2019, the US Department of Justice (“Department”) released “Guidance” describing certain steps that parties may take to earn “cooperation credit” in False Claims Act settlements. Cooperation credit refers to the government’s willingness to reduce damage multiples or “penalties” in actual FCA settlements. The Guidance will have direct […]
DHHS RFI on Reducing Regulatory Burdens
A new DHHS Request for Information on Reducing Administrative Burden to Put Patients Over Paperwork was published in the Federal Register on June 11, 2019. (84 FR 27070) The comment period is open for 60 days from the publishing date. As described in the notice, “[t]his RFI solicits additional public […]
Update on CMS Co-Location Guidance
CMS released draft guidance regarding requirements under the Conditions of Participation (“COPs”) for hospitals co-located with other hospitals and health care providers. The draft guidance was issued by the Director of the CMS Quality, Safety and Oversight Group on May 3, 2019, and is available here. CMS requested comments regarding […]