Legal and practical healthcare information.
Originally published in Healthcare Michigan, Volume 40, No. 3 As the year 2020 began, it would have been difficult for most Americans to imagine how life, as we knew it at that time, would change in the coming months and years. You likely recall generally, if not specifically, that on January 31, 2020, the Secretary of …
Continue reading “Keep the End in Sight: Expiration of the COVID-19 Declared Emergencies”
On March 10, 2022, the Department of Justice (“DOJ”) appointed a Director for COVID-19 Fraud Enforcement.[1] As a part of this announcement, DOJ announced some of its priorities in Health Care Fraud enforcement. The priorities focus on kickbacks, utilizing the relaxed rules to bill for medically unnecessary or never performed services, vaccine-related fraud, and fraud …
As employees return to the workplace, an increasing number of employers are asking their workers to provide proof of their COVID-19 vaccinations. This has led to many questions and concerns about whether such a practice is permitted under various healthcare privacy laws, particularly the Health Insurance Portability and Accountability Act (“HIPAA”). At first glance, the …
On May 3, 2021, the U.S. Department of Health & Human Services (“HHS”) announced the creation of the COVID-19 Coverage Assistance Fund (“CAF”).[i] Providers who administered the vaccine to patients on or after December 14, 2020, can now seek reimbursement for certain amounts they were unable to bill to patients for administering the vaccine. For …
Continue reading “HHS Announces the COVID-19 Vaccine Coverage Assistance Fund”
In March 2020, Congress passed the Coronavirus Aid, Relief and Economic Security (“CARES”) Act, which provided $2.2 trillion in economic relief. The Act was designed to quickly get money to millions of Americans suffering from the pandemic. Unfortunately, this relief provided ample opportunity for fraud. As the COVID pandemic begins to ease, the Department of …
Continue reading “Department of Justice Increases Focus on COVID-19 Fraud”
The American Rescue Plan (ARP) provides $1.9 trillion dollars in economic stimulus for individuals, certain companies, and municipalities. This blog focuses specifically on what the ARP means for employers. First Coronavirus Response Act (FFCRA) As of January 1, 2021, employers who were originally covered under the FFCRA (employers with fewer than 500 employees) were no …
Continue reading “What the American Rescue Plan Means for Employers”
With two COVID-19 vaccines set to receive federal approval in the United States in the upcoming weeks, the next question is whether employers can make employees receive the vaccine. The short answer is…yes. And while the typical lawyer answer to any question is “it depends,” that concise “yes” does come with a few caveats. So, …
Continue reading “Can Employers Make Employees Get the COVID-19 Vaccine?”
The Office of the Inspector General (“OIG”) for the Department of Health and Human Services (“HHS”) has developed a process for interested parties to obtain regulatory compliance guidance from the OIG prior to pursuing arrangements related to COVID-19. The OIG has dubbed this process FAQs–Application of OIG’s Administrative Enforcement Authorities to Arrangements Directly Connected to the Coronavirus Disease …
On July 13, 2020, Michigan Governor Gretchen Whitmer issued Executive Order (“EO”) 2020-150, which renewed and, at the same time, rescinded different relief measures previously granted to health care professionals in Michigan during the COVID-19 state of emergency. On April 1, 2020, to increase access to care in response to COVID-19, the Governor issued EO …
Continue reading “Michigan Governor Rescinds Some and Extends Other Scope of Practice Rules”
Over the past few months the State of Michigan along with the world has been stricken by a pandemic not seen for the last 100 plus years. Throughout the last few months the learning curve has been steep while the best medical and scientific minds have struggled to learn everything possible about the disease. In …