On November 6, 2023, the HHS Office of Inspector General published a new compilation of compliance guidance under the title General Compliance Program Guidance (GCPG) for the healthcare compliance community and other health care stakeholders. Consistent with the OIG’s April 24, 2023 announcement of its plan to issue modernized, improved, and accessible guidance, the 91-page document... Continue Reading…More

The federal No Surprises Act and interim final rules implementing the Act went into effect on January 1, 2022. Part I is aimed at reducing “surprise bills” to patients in the context of services provided at hospitals and ambulatory surgical centers. A “surprise bill” is one that a patient receives for services from a provider... Continue Reading…More

On January 13, 2022, by a vote of 5-4, the U.S. Supreme Court stayed a pair of injunctions that had prevented implementation of the CMS Vaccine Mandate in 24 states. The Supreme Court’s ruling means that, for now, the CMS Vaccine Mandate should be in effect nationwide.1 How Did We Get Here? On November 1,... Continue Reading…More

To assist health care providers that will soon be required to enforce a COVID-19 vaccine mandate, the Centers for Medicare & Medicaid Services issued guidance on December 28, 2021 regarding updated timelines for compliance and available enforcement remedies. As noted in our December 16, 2021 alert, the Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule or “CMS... Continue Reading…More

A nationwide injunction that prevented a health care worker COVID-19 vaccine mandate from taking effect has now been narrowed by a federal appellate court to apply only in the states involved in the lawsuits against the Centers for Medicare & Medicaid Services (CMS). As outlined in our prior alert, a federal judge in Louisiana issued a... Continue Reading…More

In a preliminary injunction issued on Tuesday, November 30, 2021, a federal judge in Louisiana temporarily blocked the implementation and enforcement of an interim final rule by the Centers for Medicare & Medicaid Services (CMS) that would require employees of Medicare and Medicaid certified health care providers and suppliers to have an initial COVID vaccine... Continue Reading…More

In a preliminary injunction issued on Monday, November 29, 2021, a federal judge in Missouri blocked the implementation and enforcement in 10 states of an interim final rule by the Centers for Medicare & Medicaid Services (CMS) that would require employees of Medicare and Medicaid certified health care providers and suppliers to have an initial... Continue Reading…More

The Centers for Medicare & Medicaid Services (CMS) has published the Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule, requiring vaccination of all staff at health care facilities that participate in the Medicare & Medicaid programs, regardless of responsibility or patient contact. The following summarizes who must abide by the regulations and what covered providers/suppliers need... Continue Reading…More