McGuireWoods 8th Annual Business & Legal Issues in Dialysis & Nephrology Symposium

Posted by Jason Greis on February 22, 2010 under Events | Be the First to Comment

Wednesday, May 12, 2010
7:30 a.m. – 5:30 p.m.
Westin Chicago O’Hare
6100 River Road
Rosemont, Illinois 60018 Read More...

LTACH Medical Director and Medical Center Employees Receive Fines and Probation for HIPAA Violations

Posted by Jason Greis on December 5, 2009 under Articles | Be the First to Comment

In October 2009, a Federal judge in Arkansas sentenced the medical director of an Arkansas hospital-within-hospital LTACH and an account representative and emergency unit coordinator of the host hospital to fines and probation for violating the Health Insurance Portability and Accountability Act (“HIPAA”) by unlawfully viewing a high profile patient’s electronic medical records.  (U.S. v. Holland, E.D. Ark., No. 09-cr-168, sentencing Oct. 26, 2009; U.S. v. Griffin, E.D. Ark., No. 09-cr-169, sentencing Oct. 26, 09; U.S. v. Miller, E.D. Ark., No. 09-cr-170, sentencing Oct. 26, 2009).  Read More...

FTC Defers Enforcement of the Red Flags Rule to November 1, 2009

Posted by Jason Greis on July 29, 2009 under Articles | Be the First to Comment

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...

OIG Bars Stark-Only Violations From Self-Disclosure Protocol

Posted by Jason Greis on May 22, 2009 under Articles | Be the First to Comment

Providers, including LTACHs and physicians, can no longer resolve potential Stark law-only violations through the HHS Office of Inspector General’s Provider Self-Disclosure Protocol, unless such violations are paired with Federal Anti-Kickback violations, according to the Office of the Inspector General’s recent open letter to providers.  The letter, signed by Inspector General Dan Levinson, also notes that providers will no longer be able to get past the OIG’s front door in this context unless they anticipate a minimum kickback settlement amount of $50,000.  Read More...

Blue Cross/Blue Shield of Texas Enters Settlement Agreement with Texas Attorney General

Posted by Jason Greis on April 20, 2009 under Articles | Be the First to Comment

This is an informative article written by my colleague, Bart Walker, and posted on his healthcare weblog, the North Carolina Healthcare Report on April 17, 2009. Read More...

Hospitals, including LTACHs, and Physicians Required to Disclose Physician Ownership Beginning June 8, 2009

Posted by Jason Greis on March 16, 2009 under Articles | Be the First to Comment

On March 6, 2009, the Centers for Medicare and Medicaid Services (CMS) released a CMS Manuals System transmittal implementing a final rule from the hospital inpatient prospective payment system (IPPS) for fiscal year 2008 requiring disclosure of physician ownership or investment in physician-owned hospitals.  Effective June 8, 2009 Medicare-participating hospitals will be required to disclose physician ownership or investment information to patients when a referring physician (or his or her immediate family members) has an ownership interest in a hospital.  Physicians also will be required to disclose their ownership or investment interests (and the ownership or investment interests of their immediate family members) in all physician-owned hospitals to which a physician refers patients.  A physician’s ownership or investment interest may be through equity, debt, or other means, and includes an interest in any indirect entity that holds an ownership or investment interest in a hospital. Read More...