Articles and Blogs

Non-Network Employer Health Plans – The Struggle Continues

[07/07/17]

Posted on July 7, 2017 in Health Law News

Published by: Hall Render

With employee health plan costs continuing to rise at an alarming rate, medium-sized employers are increasingly rejecting traditional insurance models built around a network of preferred providers and turning to a non-network model wherein the plan appoints a pricing consultant as a “Designated Decision Maker” (“DDM”) with discretionary and ultimate decision-making authority for determining the…Read More

When the Department of Labor Pays a Visit

[07/05/17]

Posted on July 5, 2017 in HR Insights for Health Care

Published by: Hall Render

All employers know that the U.S. Department of Labor (“DOL”) is the agency responsible for enforcement of the Fair Labor Standards Act – the federal law establishing minimum wage and overtime requirements for nearly every employer in the country. What you may not know is that the DOL can audit your workplace with or without notice. The…Read More

Hall Render’s This Week in Washington – June 30, 2017

[06/30/17]

Posted on June 30, 2017 in Federal Advocacy

Published by: Hall Render

Senate Delays Vote on BCRA On June 27, Senate majority leader Mitch McConnell (R-KY) announced the Senate would delay voting on the Better Care Reconciliation Act (“BCRA”). The Senate was scheduled to vote Wednesday on a motion to proceed with debate on its version of legislation to repeal a significant portion of the Affordable Care Act….Read More

Opinion Letters, Joint Employment and Other Changes at the Department of Labor

[06/30/17]

Posted on June 30, 2017 in HR Insights for Health Care

Published by: Hall Render

On June 27, in an anticipated move, the U.S. Secretary of Labor Alexander Acosta announced that the Department of Labor (“DOL”) will reinstate the issuance of opinion letters. The letters were a practice of the DOL for more than 70 years until 2010 when they were eliminated during President Obama’s administration in favor of broader…Read More

Reasonable Assurance Period and Voluntary Termination When an Enforcement Action Is Pending Against a Medicare Certified Provider or Supplier

[06/29/17]

Posted on June 29, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On June 16, 2017, CMS issued transmittal S&C: 17-35-ALL. This transmittal clarified CMS policy by stating a reasonable assurance period will apply if a provider or supplier voluntarily terminates its Medicare certification when an enforcement action has been initiated by the State Survey Agency. Section 2016 of the State Operations Manual allows a provider or…Read More

CMS Proposes Format Changes for Plans of Correction and Allegations of Compliance

[06/28/17]

Posted on June 28, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On June 16, 2017, CMS issued transmittal S&C: 17-34-ALL. This transmittal set forth changes to the format of Plans of Correction (“POC”) and Allegations of Compliance (“AOC”). Providers will no longer be required to write their POC/AOC on the right side of the CMS Form 2567 (“2567”). Providers are now allowed to submit the POC/AOC…Read More

Supreme Court Grants Partial Stay of Travel Ban, Allows Parts of the Travel Ban to Take Effect

[06/27/17]

Posted on June 27, 2017 in Health Law News

Published by: Hall Render

On June 26, the Supreme Court granted certiorari to review the current administration’s executive orders barring people from certain countries from entering the United States. The Court granted a stay of the executive orders in part but will allow some people to be stopped at the border under the executive orders while the case is…Read More

Hall Render’s This Week in Washington – June 23, 2017

[06/23/17]

Posted on June 23, 2017 in Federal Advocacy

Published by: Hall Render

Senate Releases Draft ACA Repeal and Replace Bill On June 22, the Senate released its version of legislation that would repeal and replace significant portions of the Affordable Care Act (“ACA”). The 142-page discussion draft, titled the Better Care Reconciliation Act (“BCRA”), is the first legislative text released by Senate leadership to repeal the ACA,…Read More

Hall Render AHLA Briefing on Compliance Program Effectiveness

[06/22/17]

Posted on June 22, 2017 in Health Law News

Published by: Hall Render

In case you missed it, on June 16, the American Health Lawyers Association released a comprehensive member briefing entitled “The OIG’s Resource Guide: An Important New Tool for Measuring Compliance Program Effectiveness”[1] (Compliance Program Briefing). The Compliance Program Briefing was authored by four Hall Render attorneys. A copy of the Compliance Program Briefing can be…Read More

Implementing Tailored Supply Chain Strategies to Jump Start Supply Chain Cost Savings

[06/22/17]

Posted on June 22, 2017 in Health Law News

Published by: Hall Render

Health system supply chain departments (and increasingly more C-suite leaders) appreciate the potential savings that standardization and centralization can generate for their organization given that 30 to 50 percent of their budget is associated with supply chain costs. However, implementing strategies and procedures, or even knowing where to start in order to generate these savings, can…Read More