After its passage in the California Senate on August 31, 2024, Assembly Bill No. 3129 (AB 3129) is now headed to Governor Newsom’s desk.
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Key Telehealth Updates in the CY 2025 Physician Fee Schedule Proposed Rule
On July 31, 2024, the Centers for Medicare & Medicaid Services (“CMS”) issued its proposed rule (“Proposed Rule”) for the 2025 Medicare Physician Fee Schedule, which includes implications for telehealth services reimbursable by Medicare. Although the majority of telehealth waivers enacted during the COVID-19 public health emergency (the “PHE”) are set to expire at the end…
Having Trouble Recruiting Physicians? The Conrad 30 Window is Opening Soon
The U.S. has long had a shortage of physicians in various practice areas. The shortage is even more pronounced in rural areas. International medical graduates (IMG’s) who come to the U.S. to complete a residency in a specialty area primarily come to the U.S. on J-1 visas. By statute, any physician who enters the U.S. on…
Navigating the Complex Landscape of AI Governance: Principles and Frameworks for Responsible Innovation
In an era where artificial intelligence (AI) is reshaping landscapes in the healthcare industry and beyond, understanding the governance of AI technologies is paramount for organizations seeking to utilize AI systems and tools. AI governance encompasses the policies, practices, and frameworks that guide the responsible development, deployment, and operation of AI systems and tools within…
Election 2024 Coverage: Examining the Future of Healthcare and Antitrust
Leading up to the U.S. presidential election this November, our Antitrust & Competition team will offer thoughts and insights into what antitrust enforcement will look like under the next presidential administration. While there is at least some uncertainty regarding antitrust enforcement under either a Harris or Trump administration, there is no doubt that the current Biden…
Update: OHCA Approves Amendments to Cost and Market Impact Review (CMIR) Regulations
California’s Office of Health Care Affordability (OHCA) has officially approved amendments (“Amendments”) to the cost and market impact review (CMIR) regulations, effective August 22, 2024. Most significantly, these Amendments expand the scope of health care entities (HCEs) subject to a CMIR, among other notable changes discussed below.…
Key Elements of an AI Governance Program in Healthcare
On August 21, 2024, Sheppard Mullin’s Healthy AI team conducted a CLE webinar on what hospitals, health systems and provider organizations should consider in building an artificial intelligence (“AI”) governance program. As they discussed, key elements of an AI governance program include: (1) an AI governance committee, (2) AI policies and procedures, (3) AI training, and…
Attention Maryland Providers: Are You Availing Yourselves of Regulatory Flexibilities under the TCOC Model?
An April 2024 independent[1] report (“Report”) analyzed the results of the first four years following implementation of the Maryland Total Cost of Care Model (the “TCOC Model”), finding that between 2019 and 2022 (the “TCOC Measuring Period”), the TCOC Model reduced Medicare spending, hospital admissions, and health disparities. CMS also distributed a summary of the…
Building a Robust AI Governance Program in Healthcare
As artificial intelligence (AI) continues to transform the healthcare industry, hospitals, health systems, and provider organizations are increasingly recognizing the need for effective AI governance. But what exactly is AI governance, and why is it so crucial for healthcare organizations?…
IRS Audits & Ongoing Scrutiny of Nonprofit Hospitals – Key Background & Action Steps
The IRS is underway with conducting audits of 35 Section 501(c)(3) tax-exempt hospitals, with a particular focus on “community benefit,” as the IRS announced in June 2024. Targeted hospitals appear to be those who reported low community benefit percentages on their IRS Form 990.…