CLIENT ADVISORY: New Conditions of Participation for Nursing Facilities Require Changes to Admission Agreements

November 23rd, 2016
Contributor: Peter Mellette
The new Conditions of Participation published by the Centers for Medicare and Medicaid Services (CMS) on October 4, 2016 require nursing facility providers to make a number of changes to their policies, procedures, agreements and operations in advanc… Read More
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Categories: Client Advisory

CLIENT ADVISORY: CMS Publishes Final Rules for Nursing Facility Requirements for Participation in Medicare and Medicaid

October 19th, 2016
Introduction On October 4, 2016, the Department of Health and Human Services (HHS) Centers for Medicare and Medicaid Services (CMS) published a Final Rule to revise Medicare and Medicaid participation requirements for nursing facilities.1 The regulat… Read More
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Categories: Client Advisory

CLIENT ADVISORY: Immediate Imposition of Federal Remedies: CMS Makes Changes Affecting Timing of Survey CMPs

August 26th, 2016
On July 29, 2016, the Centers for Medicare and Medicaid Services (CMS) released advance guidance and revisions to Chapter 7 of the State Operations Manual (SOM) regarding mandatory, immediate federal enforcement remedies for certain deficiencies and… Read More
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Categories: Client Advisory

CLIENT ADVISORY: Preparing for HIPAA Phase 2 Audits

June 28th, 2016
This year, the Office of Civil Rights (“OCR”) rolls out its HIPAA Phase 2 Audits. Phase 2 audits will review both Covered Entities (“CEs”) and their Business Associates (“BAs”) and analyze their policies and procedures’ consistency with… Read More
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Categories: Client Advisory

CLIENT ADVISORY: “You Don’t Know What You Don’t Know”: Providers Now May Be Subject to False Claims Act Liability Based on a Subjective Government Materiality Standard

June 23rd, 2016
The unanimous June 16, 2016 Supreme Court decision in Universal Health Services, Inc. v. United States and Massachusetts, ex. rel. Julio Escobar and Carmen Correa (“Escobar”) significantly expands provider exposure to liability under the False Cl… Read More
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Categories: Client Advisory