OIG issues Special Fraud Alert on business arrangements with physician-owned entities *

USA - April 12 2013
On March 26, the HHS Office of Inspector General (OIG) issued a Special Fraud Alert (Fraud Alert) reiterating its long-standing concern that the…

Co-authors: Elizabeth M. Mills, Richard J Zall, Ellen H Moskowitz, Malcolm J Harkins, III, Herschel Goldfield.

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New York State agencies again revise proposed regulations limiting use of state funds for administrative expenses and executive compensation by service providers as of July 1, 2013 *

USA - April 8 2013
Implementing Executive Order 38 issued by Governor Cuomo early in 2012, thirteen New York State agencies have again released revised proposed…

Co-authors: Elizabeth M. Mills, Michael S Sirkin, Andrew Merten.

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HHS issues HIPAA/HITECH Omnibus Final Rule ushering in significant changes to existing regulations *

USA - January 29 2013
"Sweeping changes" is how Leon Rodriquez, of the Department of Health and Human Services Office of Civil Rights (OCR), characterized the effect of…

Co-authors: Richard J Zall, Kristen J Mathews, Ellen H Moskowitz, Ryan P Blaney, Herschel Goldfield.

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Revised proposed New York regulations limit use of state funds for administration expenses and executive compensation by service providers as of April 1, 2013 *

USA - January 8 2013
Implementing Executive Order 38 issued by Governor Cuomo early in 2012, thirteen New York State agencies have now released revised proposed regulations…

Co-authors: Elizabeth M. Mills, Michael S Sirkin, Andrew Merten.

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A warning regarding impermissible arrangements between anesthesiologists and ASCs – but a warning to whom? *

USA - July 10 2012
On June 1, 2012, the U.S. Department of Health and Human Services, Office of Inspector General ("OIG") issued Advisory Opinion 12-06 (the "Opinion") concerning two proposals by an anesthesia services provider (the "Requestor") for restructuring its relationship with several ambulatory surgery centers ("ASCs").

Co-authors: Brian J Kinsella, Herschel Goldfield.

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