Stark Law and Anti-Kickback Statute Waivers for COVID-19

In light of the COVID-19 pandemic, on March 30, 2020, the Secretary of the U.S. Department of Health and Human Services (the “Secretary”) released blanket waivers (the “Waivers”) under Section 1135 of the Social Security Act (the “Act”) as to certain referral-related activities that would normally result in sanctions under the Federal Physician Self-Referral Law, …

CARES Act Increased Funding for the Public Health and Social Services Emergency Fund

The Coronavirus Aid, Relief, and Economics Security Act (the “CARES Act”) provided additional funding for the U.S. Department of Health and Human Services’ (“Department”) Public Health and Social Services Emergency Fund (the “Fund”) to assist health care providers. The Department’s guidance indicates that the following “providers” that would qualify for funds are large organizations and …

CORONAVIRUS (COVID-19) PRECAUTIONS FOR EMPLOYERS

It is now impossible to avoid the reality that the coronavirus disease 2019 (COVID-19, the “coronavirus”), is a “public health emergency of international concern,” according to the Centers for Disease Control and Prevention (“CDC”).[i] As of publication, the coronavirus is not spreading in the community in the United States.[ii] The CDC reports that the immediate …