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Plan to Offer Free Anti-Seizure Drugs to Hospitals Could Violate Anti-Kickback Statute

On November 16, 2018, The Department of Health and Human Services Office of Inspector General posted an advisory opinion regarding a drug company's proposal to provide free product ("drug") to hospitals for the hospitals to use exclusively to treat inpatients who have been diagnosed with a form of epilepsy ("Syndrome") that may occur through the en...
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OCR and ONC Bolster the Security Risk Assessment (SRA) Tool with New Features and Improved Functionality

Patients expect not only quality health care to keep them healthy, but also trust that their most sensitive health information will be protected from threats and vulnerabilities that could lead to the compromise of one's health information. An enterprise-wide risk analysis is not only a requirement of the HIPAA Security Rule, it is also an importan...
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CMS Finalizes Changes to Empower Patient EMR Access and Reduce Administrative Burden

On August 02, 2018, the Centers for Medicare & Medicaid Services (CMS) issued final rules related to the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System. Finalized changes will support patient-centered care by reinforcing the MyHealthEData and Patients Over Paperwork initiatives. The...
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New Guidance on HIPAA and Individual Authorization of Uses and Disclosures of PHI for Research

On June 18, 2018, the Office for Civil Rights issued new guidance on HIPAA and individual authorization of uses and disclosures of protected health information (PHI) for research. The guidance explains certain requirements for an authorization to use or disclose PHI for future research and clarifies aspects of the individual's right to revoke an au...
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MEASURING COMPLIANCE PROGRAM EFFECTIVENESS

Measuring compliance program effectiveness is recommended by several authorities, including the United States Sentencing Commission (see, Chapter 8 of the United States Sentencing Guidelines). The Compliance Department is not permitted to perform these audits. Audits must be performed independently, to avoid self-policing. https://www.cms.gov/Medic...
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