10.09.19In September 2019, the Department of Health and Human Services Office of the Inspector General (OIG) posted a favorable advisory opinion, 19-05, permitting a community health center to purchase real estate from an excluded individual. The OIG decided not to impose sanctions on the proposed arrangement pursuant to the civil monetary penalties law because
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OIG provides guidance on purchasing land from excluded individuals
10.09.19In September 2019, the Department of Health and Human Services Office of the Inspector General (OIG) posted a favorable advisory opinion, 19-05, permitting a community health center to purchase real estate from an excluded individual. The OIG decided not to impose sanctions on the proposed arrangement pursuant to the civil monetary penalties law because…
OIG sets parameters for online healthcare directory
10.01.19In newly issued Advisory Opinion No. 19-04, the U.S. Department of Health and Human Services Office of Inspector General (OIG) addressed whether a technology company’s online healthcare directory for searching and booking medical appointments would violate the federal Civil Monetary Penalties Law or Anti-Kickback Statute.
Under the proposed arrangement, healthcare professionals would pay the
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HHS proposes reforms to 42 CFR Part 2 to improve substance use disorder treatment
10.01.19To broaden provider access to patients’ substance use records, the Department of Health and Human Services (HHS) recently proposed reforms to the 42 CFR Part 2 regulations.
Currently, 42 CFR Part 2 restricts access to patient records from substance use treatment programs that receive federal funding. While the rule initially sought to protect these patients
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All companies can now test where the water is warm
09.30.19The Securities and Exchange Commission announced last week that it voted to adopt a new rule that extends the “test-the-waters” accommodation (which was previously available only to Emerging Growth Companies) to all issuers.
Under the new rule, Rule 163B under the Securities Act of 1933, any issuer and any person authorized to act on its
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What PE firms, healthcare investors need to know about False Claims Act liability
09.27.19A lawsuit arising from False Claims Act (FCA) allegations was resolved last week when compounding pharmacy Diabetic Care Rx LLC, or Patient Care America (PCA), two of its executives and private equity firm Riordan, Lewis & Haden Inc. (RLH) entered into a settlement agreement to pay over $21 million to resolve the enforcement action.
Reportedly
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SAFE Banking Act passes the House of Representatives
09.26.19The Secure and Fair Enforcement Banking Act, or the SAFE Banking Act, passed the House of Representatives by a vote of 321 to 103.
The Act was originally proposed to protect banks that work with companies in the marijuana industry. However, the House vote approving the Act today came after several amendments were made to…
CMS expands disclosure requirements and increases enforcement powers in affiliation rule
09.20.19The Centers for Medicare and Medicaid Services (CMS) recently issued a final rule with comment period expanding CMS’s authority to revoke or deny providers’ and suppliers’ Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) enrollment based upon their affiliation with a sanctioned entity. The rule will go into effect on November 4, 2019, and comments…
Panic at the Disco: Where is my liquor license renewal?
09.19.19Phone lines have been lighting up with the same question from bars, restaurants, hotels, and yes, even discos.
I think I’ve renewed my liquor license on time, but have not received anything from RLPS, the on-line filing system used by the Tennessee ABC. Nary an e-mail and nothing shows in RLPS. Wassup?
Callers share a
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Federal appeals court backs injunction against religious, moral exemptions from contraceptive mandate
09.17.19The Court of Appeals for the Third Circuit has upheld a lower court ruling in Commonwealth of Pennsylvania v. President United States of America et al., which granted a nationwide preliminary injunction against religious and moral exemptions for employers to the Affordable Care Act’s (ACA) contraceptive mandate.
In the opinion written by Circuit Judge Patty Shwartz,
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