What’s New with the 2-Midnight Rule?

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Executive Summary CMS recently published its CY 2016 Hospital OPPS and ASC Proposed Rule in which it proposes to create a new exception under the 2-Midnight Rule. The 2-Midnight Rule provides that hospital inpatient admissions are generally payable under Medicare Part A if the admitting physician (or other admitting practitioner)... Continue Reading →



USCIS Issues New Guidance on Amended H-1B Petitions for Worksite Changes

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Executive Summary A recent policy memorandum issued by the U.S. Citizenship and Immigration Services (“USCIS”) sets binding precedent for notifying USCIS and the Department of Labor when beneficiaries are relocated to new worksites in geographical areas not specified in original H-1B petitions.  Under this memorandum, when a beneficiary’s new worksite... Continue Reading →


Double Trouble: Lack of Safeguards with Internet Document Sharing Application and Mobile Devices Results in $218,400 HIPAA Settlement for Hospital

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Two separate alleged HIPAA violations resulted in an enforcement action by the Department of Health and Human Services (“HHS”) against a Massachusetts hospital (“Hospital”).  On July 10, 2015, the HHS Office for Civil Rights (“OCR”) announced a $218,400 settlement with the Hospital to resolve HIPAA investigations into two issues:... Continue Reading →

DOL Says “Most Workers Are Employees,” Not Independent Contractors

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On July 15, 2015, the U. S. Department of Labor (“DOL”) issued a Wage and Hour Division Administrator’s Interpretation that reasserts the broad definition of employee such that employers will rarely find that the individuals who work for them can be classified as independent contractors. This interpretation, although not having... Continue Reading →

This Week in Washington – July 17, 2015

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CMS Issues Proposed Rule for Long-Term Care Facilities On July 13, CMS issued a 403-page proposed rule that if finalized would be the most comprehensive set of revisions to long-term care facilities since 1991.  The proposed regulations would affect a wide range of issues including hospital admissions, initiatives to prevent infections, the... Continue Reading →

CMS Proposes Comprehensive Revision of LTC Requirements for Participation: Review of New Regulations for Facilities

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Introduction CMS has proposed a comprehensive revision of the requirements for participation for long-term care facilities (the “Requirements”) for the first time since 1991.  The proposed regulations reflect the significant changes in technology, resident care and facility demographics since 1991.  CMS states the proposed regulations are designed to optimize resident... Continue Reading →