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Please Click HerePosted on January 11, 2023 by Sara J. Ackermann and Nicole L. Stangl
Dear Ruder, we are getting lots of long emails from various sources about this proposed noncompete ban. Can you please break this down in easy-to-read language so we don’t have to review the entire 216 pages of the FTC’s proposed rule? Dear Reader, Yes we can! See our answers to some frequently asked questions below! […]
Posted on January 6, 2023 by Sara J. Ackermann
The Federal Trade Commission (FTC) started the new year off with a bang when it announced in a press release on January 5, 2023 that it is proposing a new rule that would ban many employee non-compete clauses. The press release follows a 3-1 vote by the FTC to publish a notice of proposed rulemaking […]
Posted on January 4, 2023 by Ruder Ware Alumni
In a September 2022 brief concerning program integrity, the Health and Human Services Office of Inspector General (OIG) identified seven measures to identify providers who may present a high risk for improper Medicare telehealth billing. These seven factors should serve as a guide to providers and their compliance officers when identifying potential fraud risk in […]
Posted on December 28, 2022 by Ruder Ware Alumni
One of the biggest challenges a compliance officer faces is establishing a strong commitment to creating a culture of compliance and obtaining recognition–there needs to be a compliance “tone from the top” of an organization. There are numerous potential challenges to getting buy-in for this concept. This can create frustration for compliance officers aware of […]
Posted on December 20, 2022 by Ruder Ware Alumni
Earlier this month, the United States Department of Health and Human Services’ Office of Civil Rights (“OCR”), the organization that has jurisdiction over enforcement of the Health Insurance Portability and Accountability Act of 1996 (the Federal law that we all know and love under the name HIPAA), released a bulletin (Bulletin) addressing the use of […]
Posted on September 21, 2022 by Ruder Ware Alumni
In September 2022, the United States Department of Justice (DOJ) released a memorandum from Deputy Attorney General Lisa Monaco that included significant changes to the way the DOJ handles corporate criminal enforcement. The (Monaco Memorandum) built upon and expanded the DOJ’s manner of handling so-called “white collar” crimes and provides guidelines for federal prosecutors across […]
Posted on August 15, 2022 by Ruder Ware Alumni
On July 29, 2022, the U.S. Department of Justice (DOJ) and the Department of Health and Human Services (HHS) jointly released “Guidance on Nondiscrimination in Telehealth: Federal Protections to Ensure Accessibility to People with Disabilities and Limited English Proficient Persons” (Telehealth Guidance). The complete Telehealth Guidance can be accessed on the HHS Website. The Telehealth […]
Posted on August 5, 2022 by Ruder Ware Alumni
The Office of Inspector General (“OIG”) has issued a Special Fraud Alert covering potential fraudulent arrangements involving companies providing telemedicine services. This Special Fraud Alert comes at a time telehealth is seeing a great deal of expansion on the heels of the COVID pandemic. In the Special Fraud Alert, the OIG focuses on fraud schemes […]
Posted on July 14, 2022 by Ruder Ware Alumni
The Centers for Medicare & Medicaid Services (CMS) issued its 2023 Physician Fee Schedule Proposed Rule seeking public comment on various policy changes impacting payment and process under Medicare Part B. The proposed rules were published on July 7, 2022. A large part of the focus of the proposed rule changes involves the expansion of […]
Posted on May 9, 2022 by Ruder Ware Alumni
Although it is unclear if the arrangement would be endorsed after the end of the COVID-19 pandemic, the Office of Inspector General (OIG) has issued a favorable opinion to a Federally Qualified Health Clinic (FQHC) planning to loan free smartphones to patients to facilitate telehealth services with providers at the FQHC. The Advisory Opinion was […]