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October 17, 2014
The October 31st deadline to review and revise your tax allocation agreement is rapidly approaching. Banks and their holding companies need to ensure their agreements are in compliance with new regulatory guidance that, amongst other things, expressly acknowledges an agency relationship exists between the entities.
October 17, 2014
October 16, 2014
Citing that “most teens who abuse pain relievers say they get them from family and friends,” the use of prescription pain drugs continues to take center stage and has spurred an Ohio law requiring new procedures when prescribing opioids to minors.
October 9, 2014
On October 9, 2014, the Centers for Medicare and Medicaid Services (CMS) issued a Proposed Rule revising current conditions of participation (CoPs) that home health agencies (HHAs) must meet in order to participate in the Medicare and Medicaid programs. This is the first time the home health regulations have been significantly revised since 1989.
October 7, 2014
The Drug Enforcement Administration’s (DEA) new regulations, aimed to cut down on prescription drug abuse, will soon allow patients to return unused pharmaceuticals to authorized locations. The new rules go into effect October 9, 2014.
October 3, 2014
On October 3, 2014, the U.S. Department of Health and Human Services of the Office of Inspector General (OIG) issued a Proposed Rule amending both the safe harbors to the anti-kickback statute and the civil monetary penalty (CMP) rules. The Proposed Rule would add new safe harbors, codify revisions to the definition of “remuneration,” and add new regulatory text interpreting the Gainsharing CMP provisions. Taking note of Congress’ intention that the safe harbor regulations be updated periodically to reflect changing business practices and technologies in the health care industry, the Proposed Rule reflects OIG’s desire to protect certain arrangements that it believes enhance effective delivery of health care and provide low risk to the Federal health care programs.
September 30, 2014
On September 26, 2014, President Obama signed into law House Resolution 2600 that adds the sales of condominium units to the list of “partial” exemptions under the Interstate Land Sales Full Disclosure Act (ILSA).
September 25, 2014
Nearly $2.5 billion dollars in overpayments were made to Skilled Nursing Facilities (“SNFs”) as a result of billing errors last year. The billing error rate for SNFs jumped to 7.7 percent, virtually doubling in 2013. According to CMS, the majority of these billing errors arise from the SNF’s repeated failures to obtain necessary certification and re-certification statements from physicians and non-physician providers (collectively “Providers”).
September 24, 2014
September 23, 2014
On September 18, 2014, the Occupational Safety and Health Administration ("OSHA") published a Final Rule relating to injury and illness reporting, that includes significant changes to the reporting requirements. The revisions represent the first modifications to reporting rules for Federal jurisdiction states since 2001. Some state-authorized OSHA programs already have reporting requirements in place that are similar to the new Final Rule, which becomes effective January 1, 2015 in Federal jurisdiction states.