The Peril of Policies

  August 28, 2020 | By David Glaser, JD For the compliance-oriented, there is something rewarding about developing policies. It feels like an accomplishment, demonstrable proof of a desire to do the right thing. But speaking as a lawyer, I am convinced that most policies hurt, rather than help, the organization that adopts them. There…

OIG HHS Audits Resuming

  August 21, 2020 | By Jesse Overbay, JD On March 13, 2020, the President of the United States issued an emergency declaration under the Stafford Act to declare a national health emergency, setting in motion a chain of events for the Centers for Medicare and Medicaid Services (“CMS”) and our entire healthcare system that…

Compliance Tidbit: How Covered Providers May Contact Patients with COVID About Population-Based Activities

  August 7, 2020 | By By Rachel Rose, JD, MBA The Health Information Portability and Accountability Act, Pub. L. 104-191 (Aug. 1996) (“HIPAA”) is often times misapplied. Take the COVID-19 pandemic for example. Despite the U.S. Department of Health and Human Services (“HHS”) and the Office for Civil Rights (“OCR”) reiterating the exceptions present…