November 17, 2023 | By Amanda Waesch This past September 2023, the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) issued Advisory Opinion 23-06 (AO).1 The Opinion involved a proposed arrangement between an independent pathology laboratory and third-party physician laboratories for the purchase of the technical component of…
April 23, 2021 | By By Rachel Rose, JD, MBA Early in 2019, the U.S. Department of Health and Human Services – Office for Civil Rights (HHS-OCR) announced the creation of an initiative to target violations of 45 CFR §164.524(b)(2) for not providing an individual with his/her requested protected health information (PHI) within…
April 9, 2021 | By Amanda Waesch In December 2016, Congress passed the 21st Century Cures Act (often simply called the “Cures Act”). Woven within the Cures Act is Section 4004 titled “Information Blocking.”[1] The purpose of this section is to prohibit any action or practice that interferes with or prevents access to electronic…
November 13, 2020 | By Bryan Meek, Esq., Brennan, Manna, and Diamond As the COVID-19 pandemic continues to wreak havoc globally, routine COVID-19 testing of employees, patients, and the general population have become more common. However, issues regarding coverage for this testing are starting to emerge. In recent weeks, major payers and insurers have…
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…