Healthcare Industry Sees Increase in Malware Attacks

By Craig Phillips In the last couple of weeks, numerous large health organizations, including hospitals, have been the target of malware attacks. Last night, MedStar, which operates ten hospitals in Washington, D.C. and Maryland was hit with malware and had to take all of their computer systems, including every station in every hospital offline. MedStar, …

Analysis of New Timeshare Arrangement Exception to the Stark Law – Part 2

By Marki Stewart In a previous post, we analyzed the new Timeshare Arrangement exception to the Stark law that CMS proposed and went into effect on January 1, 2016. Here we give an example of how the new timeshare arrangement exception works as it relates to rental of office space. Client’s Block Lease A client …

Analysis of New Timeshare Arrangement Exception to the Stark Law – Part 1

By Marki Stewart On July 15, 2015, the Centers for Medicare & Medicaid Services (CMS) proposed a series of rules that would create new exceptions to the Stark law, in addition to clarifying other provisions of the Stark law. One of the newly created exceptions is for “Timeshare Arrangements.” (effective January 1, 2016). This exception …

Physician Compliance Programs: What you need to know about the Final 60-Day Rule

By Rose Willis The 60-Day Rule was enacted as part of the Affordable Care Act on March 23, 2010 and generally requires a person who has received an overpayment to report and return the overpayment by the later of (i) the date which is 60 days after the date on which the overpayment was identified; …