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HTMLProvider Confusion and Interoperability Concerns Prompt OCR and ONC to Release Guidance on PHI Sharing
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
February 25, 2016, previously published on February 22, 2016
Last Friday, the U.S. Department of Health and Human Services Office of the National Coordinator for Health IT (“ONC”) and the Office for Civil Rights (“OCR”) released two fact sheets regarding permitted uses and disclosures of protected health information...

 

HTMLCMS Notifies States of AMP Rule Requirements: 340B Providers Should Take Note
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
February 25, 2016, previously published on February 16, 2016
Last week, Mintz Levin and ML Strategies released a joint Alert analyzing key provisions of the Covered Outpatient Drug final rule (“Final AMP Rule”) and their impact on manufacturers, pharmacy benefit managers (“PBMs”), and pharmacies. The Alert focuses on the following...

 

HTMLHollywood Presbyterian Concedes to Hacker’s Demands in Ransomware Attack
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
February 25, 2016, previously published on February 19, 2016
In a chain of events that should be a wake-up call to any entity using and storing critical health information, Hollywood Presbyterian Medical Center (“HPMC”) has announced that it paid hackers $17,000 to end a malware attack on the hospital’s computer systems. On February 5, HPMC...

 

HTMLThe Final 60-Day Rule: the Good, the Bad, and the Ugly
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
February 24, 2016, previously published on February 12, 2016
As we announced yesterday, the Centers for Medicare & Medicaid Services (CMS) has finally published the long-awaited Final Rule governing the return of Medicare Part A and Part B overpayments within 60 days (the “Final Rule”). The proposed rule, which was published nearly four years...

 

HTMLThe Affordable Care Act’s Reporting Electronic Backbone-The AIR System
Alden J. Bianchi, Kendra Strickland; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
Legal Alert/Article
February 24, 2016, previously published on February 12, 2016
For the last half of 2015, we spent a good deal of time explaining the Affordable Care Act reporting requirements that applied to carriers and large employers. A compilation of these posts, which generally address the content of the ACA reporting requirements, is available here. This post examines...

 

HTMLStaffing Firms, Educational Organizations, and Breaks-in-Service under the Affordable Care Act Employer Shared Responsibility Rules: Proposed Changes under Notice 2015-87
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
February 24, 2016, previously published on February 12, 2016
In Q&A format, recently issued Notice 2015-87 addresses a number of pressing issues that have arisen under the Affordable Care Act (ACA), including that law’s employer shared responsibility rules, information reporting requirements, and insurance market reforms, among others. Q&A 15 of the...

 

HTMLCMS Publishes Long-Awaited 60-Day Repayment Final Rule for Identified Overpayments
Claire E. Castles, Laura F. Laemmle-Weidenfeld, Elizabeth E. Trende, Megan B. Webb; Jones Day;
Legal Alert/Article
February 24, 2016, previously published on February 2016
Four years after the initial publication of the proposed rule, the Centers for Medicare and Medicaid Services ("CMS") released the long-awaited Final Rule regarding the identification, reporting, and repayment of Medicare overpayments as required under the Affordable Care Act...

 

HTMLFinal Rule Clarifies Obligations to Report and Return Medicare Overpayments
Rick L. Hindmand, Jane Marie Pine Wood; McDonald Hopkins LLC;
Legal Alert/Article
February 22, 2016, previously published on February 16, 2016
The Centers for Medicare & Medicaid Services (“CMS”) issued a final rule on Feb.12, 2016 that requires Medicare providers and suppliers to report and return overpayments by the later of (a) 60 days after the date an overpayment is identified or (b) the due date of any corresponding...

 

HTMLCMS Takes Action Against Network Transparency While New Jersey Legislation Hits a Snag
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
February 16, 2016, previously published on February 10, 2016
Just as the Centers for Medicare & Medicaid Services (CMS) began holding federal health care plans accountable for their provider network transparency obligations, the New Jersey legislature stalled in its bid to pass a law that would require hospitals and physicians to disclose whether they...

 

HTMLWhat the Cybersecurity Information Sharing Act of 2015 Means for Your Organization
Sara Hutchins Jodka; McDonald Hopkins LLC;
Legal Alert/Article
February 16, 2016, previously published on February 9, 2016
Many people missed that, before the clock struck midnight on January 31, 2015, the Cybersecurity Information Sharing Act of 2015 (CISA), a bill that was years in the making, passed. How did so many people miss it? Well, CISA was packaged in a 2,000+ page spending bill that was not the most exciting...

 


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