OIG Issues Report Addressing Ownership Overlap Between Physician-Owned Hospitals and Physician-Owned Distributors

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Background On August 13, 2015, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a Memorandum Report (the “Report”) that examined the overlap between physician-owned hospitals (“POHs”) and physician-owned distributors (“PODs”) of spinal devices. PODs are medical device distributors whose owners are often physicians that use... Continue Reading →

OIG Issues Report Addressing Ownership Overlap Between Physician-Owned Hospitals and Physician-Owned Distributors

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Background On August 13, 2015, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a Memorandum Report (the “Report”) that examined the overlap between physician-owned hospitals (“POHs”) and physician-owned distributors (“PODs”) of spinal devices. PODs are medical device distributors whose owners are often physicians that use... Continue Reading →

Breaking: HRSA Releases Preliminary Version of Proposed 340B Omnibus Guidance

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On August 27, 2015, the Health Resources and Services Administration (“HRSA”) released a notice of proposed 340B Drug Pricing Program Omnibus Guidance.  This notice (a copy of which can be found here) proposes to establish long-awaited and significant guidance for covered entities enrolled in, and drug manufacturers participating in, the... Continue Reading →

Transition to ICD-10: 40 Days to Go

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The American Hospital Association (“AHA”) released a “homestretch” checklist to help hospitals verify that they are ready for the transition from ICD-9 to ICD-10.  The AHA recommends checking internal systems, verifying external partner readiness and consideration of financial protections.  This includes verification that their software applications have been appropriately updated to... Continue Reading →

The DOL Strikes Back: Department of Labor Wins Companionship Services Case

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On August 21, 2015, the Court of Appeals for the D.C. Circuit (the “Court”) issued a ruling in Home Care Association of America v. David Weil, also known as the “companionship services lawsuit.” Unfortunately, it is more bad news for the home care industry. The Court ruled that the Department... Continue Reading →

Nineteen Hall Render Attorneys Listed by Best Lawyers

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Nineteen Hall Render attorneys were recently selected by their peers for inclusion in The Best Lawyers in America® 2016.  Hall Render congratulates: Elizabeth Callahan-Morris, Shareholder, Best Lawyers Since 2014 Lawrence K. Coon, Shareholder, Best Lawyers Since 2007 Arthur F. deVaux, Shareholder, Best Lawyers Since 2013 Mary C. Gaughan, Shareholder, Best Lawyers... Continue Reading →

The 60-Day Vulture Comes Home to Roost

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In a judicial opinion certain to rock the provider world, Judge Edgardo Ramos of the Federal District Court for the Southern District of New York denied a New York Health System’s (“Health System”) motion to dismiss the U.S.’s and New York State’s complaints in intervention under the federal False Claims... Continue Reading →

Value-Based Purchasing Is the New Normal: Opportunities for Savings in the Supply Chain

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Executive Summary Earlier this year, the Department of Health and Human Services (“HHS”) announced significant changes to Medicare by setting quantitative goals for its value-based payment programs. This payment reform is not only accelerating the shift away from fee-for-service toward a value-based system but also driving fundamental changes in how... Continue Reading →


Hall Render’s This Week in Washington – August 7, 2015

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Congress Begins August Recess On August 5, Senate leaders determined that no further action was likely on pending legislative matters and called for the start of the August recess break.  Prior to adjourning, the Senate passed amended measures seeking an adjustment of the management of electronic health records on patient... Continue Reading →