As healthcare systems continue to adapt to an evolving landscape, the role of Advanced Practice Providers (APPs) has become increasingly important. APPs include nurse practitioners (NPs), clinical nurse specialists (CNSs), physician assistants (PAs), certified registered nurse anesthetists (CRNAs), anesthesia allergy assistants (AAs), and clinical pharmacist practitioners. With an increasing demand for care, particularly in underserved
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OIG Publishes Special Fraud Alert on Medicare Advantage Marketing Arrangements
On December 11, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) published a Special Fraud Alert warning against suspect payment arrangements involving the Medicare Advantage (“MA”) program which could implicate the Federal Anti-Kickback Statute (“AKS”), the False Claims Act (“FCA”), and other health care fraud and abuse laws. These suspect
Compliance with HIPAA’s New Protections for Reproductive Health Privacy: What Covered Entities and Business Associates Need to Know Now
On April 26, 2024, the U.S. Department of Health and Human Services (“HHS”) issued new reproductive healthcare rules, which will go into effect on December 23, 2024. The underlying goals of these rules are to ensure individuals do not forego lawful health care when needed or withhold information from providers out of fear that sensitive
SNFs Receive Additional Time to Complete Off-Cycle Revalidation
Last month, Terri Harris and I broke down The Centers for Medicare & Medicaid Services’ (CMS’s) required off-cycle revalidation of all Skilled Nursing Facilities (SNFs) in an Alert and related blog post. Since our last update, CMS has made several significant changes:
- The deadline for all SNFs to respond has been extended to May
Changing Landscape: Increasing Scrutiny and Regulation of Health Care Transactions Despite the California AB 3129 Veto
Introduction
California Assembly Bill 3129 (“AB 3129”) would have targeted private equity and hedge fund investment in health care entities specifically. It would have required private equity and hedge fund groups to provide 90 days pre-closing notice and obtain consent from the California Attorney General (“AG”) prior to a change of control or
The John W. Rheay Act: A Step Forward in Florida’s Fight Against HIV
Introduction
In a significant move to enhance public health and expand HIV prevention measures, Florida has recently enacted the “John W. Rheay Act” (Fla. Stat. § 465.1861), effective as of July 1, 2024. This legislation aims to enhance access to critical healthcare services, reduce barriers to HIV prevention, and promote proactive health management
Attention SNFs: Be on the Lookout for CMS Off-Cycle Revalidation
The Centers for Medicare & Medicaid Services (CMS) recently announced it will require off-cycle revalidation for all Skilled Nursing Facilities (SNFs). During this process, CMS will collect ownership, management, and related party information that was not previously required to be disclosed. CMS is giving SNFs only 90 days to respond.
When will it happen? Why
CMS Proposed Rule Decreases Physician Payments, Expands Telehealth, and Much More
The comment period for the CMS CY 2025 Physician Fee Schedule (PFS) Proposed Rule recently closed on Monday, September 9th. Based on previous years, the Final Rule can be expected as soon as early November, taking effect January 1, 2025. The Proposed Rule contains changes to various policies as well as extensions of policies set
Pennsylvania Limits Non-Competes for Most Health Care Practitioners and Requires Patient Disclosure Upon Departure
Beginning on January 1, 2025, employment-based non-compete covenants will be unenforceable against physicians, certified registered nurse practitioners, physician assistants and certified registered nurse anesthetists (each, a “practitioner”) in Pennsylvania, unless the non-compete covenant is for less than one year in duration and the practitioner was not “dismissed” by the employer. The Fair Contracting for Health
The CFPB’s Continued Spotlight on Medical Debt Emphasizes the Importance of Proper Provider Billing
Last month, the Consumer Financial Protection Bureau (CFPB) issued its 2023 Annual Report on the Fair Debt Collection Practices Act (FDCPA), which notes the CFPB’s activities and observations related to debt collection in 2022. The CFPB is continuing its trend of focusing its attention on medical debt.
The CFPB claims that the collection, furnishing,