Word Of Caution To HIPAA Hybrid Covered Entities: NYS Shield Act Amends NYS Breach Notification Law, Adds Data Security Requirements, Imposes Data Security Obligations For Hybrid Covered Entities Thursday, November 14, 2019 On July 25, 2019, New York Governor Andrew Cuomo signed the Stop Hacks and Improve Electronic Data Security Act (the "SHIELD Act"), making key changes to New York's data breach notification and cybersecurity laws. Read more
Fair Market Value and Anti-Kickback Statute Considerations for Physician Lease Arrangements Wednesday, October 16, 2019 In a recent ruling from the U.S. Court of Appeals Eleventh Circuit, a whistleblower suit was decided in favor of the defendant because the relator failed to prove a lack of fair market value consistent with Federal Civil Rule 9(b) particularity requirements. Read more
DOJ Cooperation Credit Guidance: What is the Benefit of Cooperation? Monday, May 20, 2019 The U.S. Department of Justice (DOJ) issued policy guidance on May 6, 2019, about providing credit in False Claims Act (FCA) settlements to corporations for "disclosure, cooperation, and remediation." See https://www.justice.gov/jm/jm-4-4000-commercial-litigation#4-4.112. Read more
The Department of Justice in April 2019 Updated Guidance for Evaluating Corporate Compliance Programs Thursday, May 2, 2019 How does your Organization respond to the three fundamental compliance questions? Read more
2018 All-Time Record Year for HIPAA Enforcement Tuesday, April 16, 2019 The Office of Civil Rights recently reminded us of the importance of HIPAA privacy and the cost of neglect. In a February 7, 2019, posting the Office for Civil Rights (OCR) concluded an all-time record year in HIPAA enforcement activity. Read more