Publications

The Centers for Medicare and Medicaid Services (“CMS”) recently released eight frequently asked questions concerning the Self-Referral Disclosure Protocol (“SRDP”). The SRDP is a product of the Patient Protection and Affordable Care Act of 2010 and provides a process for providers and suppliers to self-disclose violations of the physician self-referral […]

The Office for Civil Rights recently published new guidance to assist law enforcement and covered entities when addressing information sharing situations where the HIPAA Privacy Rule may be at issue. The HIPAA Guide for Law Enforcement contains an overview of the Privacy Rule and describes permitted disclosures of health information […]

The Federal Reserve has appealed a district court decision that would have vacated the Fed’s Regulation II, which implements the Dodd-Frank Act’s interchange fee cap and dual routing rule for debit cards.   On July 31, 2013, the United States District Court for the District of Columbia issued an opinion […]

The Consumer Financial Protection Bureau (“CFPB”) recently issued a bulletin on the Fair Credit Reporting Act’s (“FCRA”) requirement that furnishers of credit information investigate disputes and review all relevant information (“Bulletin”).1 Financial institutions are the most prominent “furnishers” covered by the FCRA, and the Bulletin has prompted some banks and […]

On August 15, 2013, the U.S. Environmental Protection Agency published a proposed Amendment to Standards and Practices for All Appropriate Inquiries that would approve a new standard by which Phase I Environmental Site Assessments may be conducted. In the process of acquiring real property, prospective buyers (or other potential owners or […]