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The OCR Reminds Businesses that Consequences for HIPAA Violations Do Not...

The U.S. Department of Health and Human Services (“HHS”), Office of Civil Rights (“OCR”), issued a press release recently to make the point that just because a business closes during an OCR...

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CMS Proposes Simplifying E/M Documentation Requirements to Reduce Clinician...

The Centers for Medicare and Medicaid Services (“CMS”) recently released its notice of proposed rulemaking titled “Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to...

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HHS Seeks Input From the Provider Community On Possible Changes to the...

On August 27, 2018, the Department of Health and Human Services (“HHS”), Office of Inspector General (“OIG”) published a request for information (“RFI”) seeking input from the public on how it might...

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Appellate Division Enforces The Self-Critical Analysis Privilege Protections...

On February 6, 2017, the New Jersey Appellate Division reversed a trial court ruling by holding that a hospital’s failure to notify regulators of a treatment error does not mean that the hospital loses...

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The 2017 OIG Work Plan – Areas of New Focus In the New Year

On November 10, 2016 the Department of Health and Human Services Office of Inspector General released its 2017 Work Plan. The Work Plan, which is updated annually, furnishes key guidance to providers,...

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The Office of Inspector General and the Health Care Compliance Association...

On March 27, 2017 the Department of Health and Human Services Office of Inspector General (“OIG”) and the Health Care Compliance Association (“HCCA”) released a document called Measuring Compliance...

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New Proposed Legislation Seeks To Restore Tax Exempt Status to Non-Profit...

In the wake of the 2015 court case challenging the tax exempt status of a nonprofit hospital here in New Jersey, the fight continues over this issue with many of the non-profit hospitals in New Jersey...

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Beware CMS’ Ability to Preemptively Suspend or Revoke a Provider’s License

Most providers primarily worry about the financial impact of fraud and abuse and other compliance issues. However, as occurred recently in Dallas Texas, federal and state agencies can also come for a...

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HHS Actually Takes Action to LOWER the Penalties For One Of Its Enforcement Laws

On April 29, 2019, the United States Department of Health and Human Services (“HHS”) announced in the Federal Register through a Notification of Enforcement Discretion that effective immediately, it...

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CMS’ New Rule Targets “Bad Actors” and Anyone That Associates With Them

On September 4, 2019, the Centers for Medicare and Medicaid Services (“CMS”) issued a final rule allowing it to revoke health care providers’ and suppliers’ Medicare enrollment if they are affiliated...

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