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Fifth Circuit vacates $4.3M HHS enforcement penalty for HIPAA violations

USA - February 23 2021 Last month, the US Court of Appeals for the Fifth Circuit issued a ruling vacating a $4.3 million dollar civil monetary penalty (CMP) against the…

Jennifer Pike

HHS proposes significant changes to Stark, Anti-Kickback and CMP regulations

USA - October 11 2019 On October 9, 2019, the Department of Health and Human Services (“HHS”) proposed significant amendments to the Stark Law, Anti-Kickback Law and Civil…

Lauren Pair, Christina Z. Randolph

OCR reminds business associates of direct liability for noncompliance with HIPAA Rules

USA - June 10 2019 The HHS Office for Civil Rights (“OCR”) recently issued a new Fact Sheet (“Fact Sheet”) addressing direct liability of business associates for…

CMS draft guidance on co-location arrangements: What hospitals and health care entities need to know

USA - May 29 2019 Many hospitals share space with other providers. Previously, CMS’ guidance on the permissibility of such arrangements was informal and could vary by…

Christina Z. Randolph

HHS issues voluntary health care cybersecurity guidelines

USA - January 17 2019 On December 28, 2018, the U.S. Department of Health and Human Services (“HHS”) published the “Health Industry Cybersecurity Practices (HICP):…

Jennifer Pike