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Stark Law Blanket Waivers – What is a COVID-19 Purpose?

Posted on April 27, 2020 by

The Blanket Waivers that the Centers for Medicare and Medicaid Services issued under the Stark Law apply only to financial relationships and referrals that are related to the national emergency that is the COVID-19 outbreak in the United States. Any remuneration described in the Blanket Waivers must be directly between the entity and the physician […]

CARES Act Requires Providers of COVID-19 Testing to Post Test Rates on Their Website

Posted on April 24, 2020 by

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) became law on March 27, 2020.  One provision that has not received much coverage is the requirement for providers of COVID-19 diagnostic testing to publish the cash price for the test on their website.  The requirement appears to last for the duration of the emergency […]

Stark Law Blanket Waivers – List of 18 Blanket Waivers

Posted on April 23, 2020 by

The following is a list of categories of the Stark Law Blanket Waivers permitting deviations from the provisions of the Stark Law where necessary for a COVID-19 purpose.  See Background on CMS Stark Law Waiver.   The definition of what constitutes a COVID-19 purpose is relatively broad, but there does need to be a connection that […]

Waiver Amounts Owed For Telehealth Services During The 2019 Novel Coronavirus (COVID-19) Outbreak

Posted on April 22, 2020 by

The Health and Human Services (HHS) Office of Inspector General (OIG) issued a Policy Statement on March 17, 2020 regarding the waiver of amounts owed by beneficiaries for services provided by telehealth.  Recognizing the unique circumstances resulting from the COVID-19 outbreak, the OIG states that it will not subject physicians and other practitioners to OIG […]

The EEOC Issues Another Update to its Guidance on Dealing With COVID-19 in the Workplace

Posted on April 21, 2020 by

After having just issued an update on April 9, the U.S. Equal Employment Opportunity Commission (EEOC) has now issued another update to its guidance document, “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEOC Laws.”  This has been the subject of two of our previous alerts (see The EEOC […]

CMS Issues Guidance On Resuming Non-COVID-19 Care In Areas That Have Low Incidence Of COVID-19

Posted on April 21, 2020 by

The Centers for Medicare & Medicaid Services (CMS) have issued new recommendations targeted at communities in Phase 1 of the Guidelines for President Trump’s “Opening Up America Again.”  The Phase 1 category includes communities with low incidence or relatively low and stable incidence of COVID-19 cases.  The new CMS guidelines outline recommendations for a gradual […]

How the Stark Law Waivers Can Help Combat the Coronavirus

Posted on April 17, 2020 by

The Centers for Medicare & Medicaid Services published at the end of March new blanket waivers under the federal physician self-referral law (commonly known as the Stark Law) in response to the COVID-19 pandemic.  The waivers were made retroactive to March 1, 2020 in recognition of the fact that the COVID-19 pandemic likely required some providers […]

IRS Extends 60-Day Rollover Deadline

Posted on April 17, 2020 by

In our recent blog post, The Early Bird RMD Doesn’t Get the Tax Relief Worm, we provided guidance regarding the suspension of required minimum distributions (RMDs) under the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”).  We advised that if you already took your RMD for 2020, the CARES Act may allow you […]

State of Wisconsin Extends Safer at Home Order

Posted on April 16, 2020 by , , , and

This afternoon, Wisconsin Department of Health Services issued Emergency Order #28 (the “Extended Order”), an extension to Emergency Order #12 released on March 24th (the “Original Order”). The full text of the Extended Order can be accessed here. The Original Order remains in effect until 8:00 AM on April 24th, at which time the Extended […]

Will the Stimulus Check Impact my Medical Assistance?

Posted on April 16, 2020 by

As the IRS begins to send out payments under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, recipients of Medical Assistance for long-term care (i.e., Medicaid or Family Care) are wondering how this payment may affect their benefits. In other words, will the payment be considered either income or an asset that causes issues […]