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Please Click HerePosted on April 30, 2020 by Mary Ellen Schill and Amy E. Ebeling
With a second round of Paycheck Protection Program (“PPP”) funding coming available last week, a large percentage of small businesses either have already received (or will soon receive) the proceeds of a PPP loan. At only one percent interest over two years, PPP loans present a great opportunity, but, obviously, businesses are most interested in […]
Posted on April 29, 2020 by Mark J. Bradley and Jessica A. Merkel
Maybe you were informed ahead of time or maybe you found out when you were first called upon to act. In any event, someone (a parent, a sibling, a friend, a neighbor) named you as their agent or attorney-in-fact under a Wisconsin power of attorney for finances.[1] Now what?[2] What Are Your Rights and Responsibilities? […]
Posted on April 28, 2020 by Ruder Ware Alumni
The Centers for Medicare & Medicaid Services (CMS) issued Blanket Waivers of certain requirements of the Physician Self-Referral Law (Stark Law). The purpose for the Blanket Waivers is to provide the flexibility providers need in the face of the COVID-19 pandemic. As long as the financial relationship pertains to at least one COVID-19 purpose, the […]
Posted on April 27, 2020 by Ruder Ware Alumni
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 […]
Posted on April 24, 2020 by Ruder Ware Alumni
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 […]
Posted on April 23, 2020 by Ruder Ware Alumni
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 […]
Posted on April 22, 2020 by Ruder Ware Alumni
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 […]
Posted on April 21, 2020 by Ruder Ware Alumni
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 […]
Posted on April 21, 2020 by Ruder Ware Alumni
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 […]
Posted on April 17, 2020 by Ruder Ware Alumni
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 […]