Posted by Jason Greis on November 9, 2009 under Articles | 
On Oct. 30, 2009, the U.S. Federal Trade Commission (FTC) deferred enforcement of the Red Flags Rule once again, from Nov. 1, 2009 to June 1, 2010, “at the request of Members of Congress.” However, the FTC also acknowledged that earlier that day, the U.S. District Court for the District of Columbia had enjoined the FTC from applying the Red Flags Rule to attorneys. Importantly, the FTC’s deferral does not affect the separate timeline of that legal proceeding and any possible appeals. Nor does this deferral affect other federal agencies’ ongoing enforcement for financial institutions and creditors subject to their oversight. Read More...
Tags: 2010, greisguide, greisguidetoltachs, healthcare, hospital, hr 3763, jonathan vogel, june, kenneth dort, kimberly kannensohn, larry goodall, ltac, LTACH, LTCH, mcguirewoods, provider, red flag rules
Posted by Jason Greis on October 18, 2009 under Articles |
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Tags: 3763, adler, bill, broun, creditor, greisguide, greisguidetoltachs, healthcare, hospital, house, jason greis, ltac, LTACH, LTCH, november 1, provider, red flag rules, simpson
Posted by Jason Greis on under Articles |
Recent substantive and procedural amendments to the Federal False Claims Act (“FCA”) enacted under the Fraud Enforcement and Recovery Act of 2009 (“FERA”) are expected to fuel growth in the number of whistleblower-generated cases brought against healthcare providers—including LTACHs. The FERA amendments closed a loophole in the FCA that previously prevented overpayment cases from being brought against providers. The FCA now allows whistleblowers to bring false claims actions against providers who knowingly and improperly keep government funds paid to them in error. FERA was signed into law May 20, 2009. Read More...
Tags: allison engine, attorney general, claim, contractor, fera, fraud enforcement and recovery act, greisguide, greisguidetoltachs, health care, healthcare, hospital, intent, ltac, LTACH, LTCH, Medicaid, medicare, oig, supreme court
Posted by Jason Greis on September 17, 2009 under Articles |
I. Political Overview. Read More...
Tags: accountable care organization, aco, bundled, bundling, chairman's mark, Chuck Grassley, extension, gang of six, healthcare, hha, home health, hospice, hospital, innovation center, inpatient rehabilitation, irf, jason greis, Jeff Bingaman, Kent Conrad, long term acute care hospital, long term care hospital, ltac, LTACH, LTCH, max baucus, Medicaid, medicare, Mike Enzi, mmsea, mona mohib, Olympia Snowe, overhaul bill, post-acute, quality reporting, senate finance committee, skilled nursing, snf, value-based purchasing
Posted by Jason Greis on July 29, 2009 under Articles |
On July 29, 2009, the U.S. Federal Trade Commission (FTC) deferred enforcement of the Red Flags Rule from August 1, 2009 to November 1, 2009 in order “to give creditors and financial institutions more time to develop and implement written identity theft prevention programs.” As we discussed in our articles from 4/27/09 and 5/4/09, the Red Flags Rule will require many businesses to develop, implement, and administer an Identity Theft Prevention Program that is designed to detect the warnings signs (or “red flags”) of identity theft, as well as to prevent and mitigate it. Read More...
Tags: august 1, federal trade commission, ftc, greisguide, greisguidetoltachs, healthcare, hoefling, hospital, james riley, jonathan vogel, ken dort, ltac, LTACH, LTCH, matthew, mcguirewoods, november 1, physician, red flag
Posted by Jason Greis on February 24, 2009 under Articles |
On October 22, the FTC announced that enforcement of its Identity Theft Red Flag Rules, originally scheduled to begin November 1, 2008, will now be delayed until May 1, 2009. The reason for the delay is that many entities, including health care providers, have been uncertain or even unaware of their coverage under the Rules until this point. The extension will allow covered entities more time to comply with the mandate to create and implement a written identity theft prevention program. The FTC is also planning to provide additional guidance as to Rules themselves and to which entities the Rules apply, but no date has been provided for this guidance. Read More...
Tags: covered account, creditor, elizabeth diller, FACTA, Fair and Accurate Credit Transactions Act, federal trade commission, ftc, greisguide, greisguidetoltachs, health care, health insurance portability and accountability act, healthcare, hipaa, identity theft, j. brian jackson, ltac, LTCH, mcguirewoods, nathan kottkamp, red flag rules
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