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HTMLCMS Proposes Changes to the Home Health Face-to-Face Encounter Requirement
Leslie J. Levinson, Michaela ("Kayla") Tabela; Edwards Wildman Palmer LLP;
Legal Alert/Article
July 21, 2014, previously published on July 2014
On July 7, 2014, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule updating the Home Health Prospective Payment System (“HH PPS”) rates, including the national, standardized 60-day episode payment rates, the national per-visit rates, and the...

 

HTMLSEC Provides Helpful Guidance on Accredited Investor Verification
Stacie Sawchak Aarestad, Matthew C. Dallett, Stanley Keller, Eugene W. McDermott; Edwards Wildman Palmer LLP;
Legal Alert/Article
July 14, 2014, previously published on July 2014
On July 3, 2014, the staff of the SEC’s Division of Corporation Finance issued guidance on reasonable steps to verify the accredited investor status of purchasers for purposes of the Rule 506(c) exemption that permits general solicitation. The guidance, which is in the form of several...

 

HTMLFDA Issues Draft Guidance for Medical Device Data Systems
Leslie J. Levinson, Michaela ("Kayla") Tabela; Edwards Wildman Palmer LLP;
Legal Alert/Article
July 1, 2014, previously published on June 2014
On June 20, 2014, the Food and Drug Administration (FDA) issued draft guidance to inform manufacturers, distributors, and other entities that FDA does not intend to enforce compliance with the agency’s 2011 regulations governing medical device data systems (MDDS) subject to 21 CFR...

 

HTMLMajor Amendments to Florida Breach Notification Statute: Unique Requirements and Short Deadlines Take Effect July 1
Theodore P. Augustinos, Karen L. Booth, Mark E. Schreiber, Thomas J. Smedinghoff; Edwards Wildman Palmer LLP;
Legal Alert/Article
July 1, 2014, previously published on June 2014
Florida Governor Rick Scott recently signed the Florida Information Protection Act of 2014 (SB 1524, the “Act”) into law, amending Florida’s breach notification statute effective July 1, 2014. The amendments are significant, including the first statutory requirement to provide...

 

HTMLMicrosoft and Other Major Technology Companies Push Back Against Warrant to Access Data Held on Foreign Servers
Lawrence R. Freedman, Ari Z. Moskowitz, Mark E. Schreiber; Edwards Wildman Palmer LLP;
Legal Alert/Article
July 1, 2014, previously published on June 26, 2014
A dispute between Microsoft and the U.S. government over a search warrant could have major repercussions for cloud service providers. Historically, European data privacy and protection standards have been stricter generally speaking than those in the U.S. The "Safe Harbor" arrangement...

 

HTMLLimelight v. Akamai: Illuminating Inducement of Patent Infringement
Jeffrey D. Hsi, Ralph A. Loren; Edwards Wildman Palmer LLP;
Legal Alert/Article
June 11, 2014, previously published on June 3, 2014
On June 2, the Supreme Court issued a decision regarding inducing infringement, Limelight Networks, Inc. v. Akamai Technologies, Inc., et al., (12-786). The Justices, reversing and remanding the widely split en banc decision from the Federal Circuit, held that one could not support a finding of...

 

HTMLAHA Sues over Delays in Appeals Process
Leslie J. Levinson, Michaela ("Kayla") Tabela; Edwards Wildman Palmer LLP;
Legal Alert/Article
May 30, 2014, previously published on May 2014
On May 22, 2014, the American Hospital Association (AHA) and three member hospitals filed a lawsuit against Secretary Kathleen Sebelius, in her capacity as the Secretary of the U.S. Department of Health and Human Services (HHS), in the U.S. District Court for the District of Columbia to compel HHS...

 

HTMLOIG Proposed Rules Would Expand Civil Monetary Penalty Authority and Exclusion Authority
Leslie J. Levinson, Michaela ("Kayla") Tabela; Edwards Wildman Palmer LLP;
Legal Alert/Article
May 30, 2014, previously published on May 2014
On May 12, 2014, the HHS Office of Inspector General (OIG) published a proposed rule implementing the new civil monetary penalty (CMP) authorities provided under the Affordable Care Act.

 

HTMLWhite House Supports Current Cybersecurity Rules
Leslie J. Levinson, Michaela ("Kayla") Tabela; Edwards Wildman Palmer LLP;
Legal Alert/Article
May 30, 2014, previously published on May 2014
The Obama Administration recently announced that it allow HHS to continue its efforts to mitigate cyberrisk. Last year, President Obama issued Executive Order (EO) 13636, “Improving Critical Infrastructure Cybersecurity,” which required HHS and other Executive Branch agencies to assess...

 

HTMLCMS Rejects Louisiana’s Plan to Privatize State-Owned Hospitals
Leslie J. Levinson, Michaela ("Kayla") Tabela; Edwards Wildman Palmer LLP;
Legal Alert/Article
May 8, 2014, previously published on May 2014
On May 2, 2014, CMS rejected Louisiana Gov. Bobby Jindal’s plan to privatize six state-owned hospitals in New Orleans, Lafayette, Houma, Lake Charles, Shreveport and Monroe.

 


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