HHS Delays NPP Amendment Requirement for Laboratories Regulated Under CLIA

By Scott Roberts Under the HIPAA Privacy Rule, a Covered Entity is required to revise its notice of privacy practices (“NPP”) where there is a material change to any of its privacy policies. The HIPAA/HITECH Omnibus Final Rule (the “Omnibus Rule”) issued earlier this year requires a number of changes to privacy policies that will …

New Guidance for Healthcare Providers Regarding Screening of Employees and Contractors for “Excluded Persons”

By Rose Willis Under the Federal “Exclusions Statute,” a health care provider that arranges or contracts with a person that the provider knows or should know is an excluded person, may be subject to Civil Money Penalties (“CMP”) liability, or exclusion, if the excluded person provides services that are payable, directly or indirectly, by a …

Record Recoveries Announced by DOJ and HHS

In a recent announcement, the Departments of Justice and Health & Human Services announced record recoveries of $4.2 billion in their 2012 fiscal year from healthcare fraud prevention and enforcement efforts.  This is an increase from the $4.1 billion recovered during 2011. Highlighted areas of recovery included improper billing (overpayments and for services not performed) …