On Friday April 26, 2019, the US Department of Health and Human Services (“HHS”) issued a notification regarding HHS’ use of Civil Monetary Penalties (“CMP”) under the Health Insurance Portability and Accountability Act (“HIPAA”) as amended by the Health Information Technology for Economic and Clinical Health (“HITECH”) Act. https://www.federalregister.gov/documents/2019/04/30/2019-08530/enforcement-discretion-regarding-hipaa-civil-money-penalties. The notice provides: “As a matter of enforcement discretion, and pending further ...
On June 25, 2018, the Office of the Inspector General of the Department of Health and Human Services (“OIG”) published Advisory Opinion 18-05, allowing a nonprofit medical center to provide or arrange for certain support services for individuals who care for adults with chronic medical conditions (the “Opinion”). The Opinion is significant because it helps to define the limits of recently enacted exceptions to the Civil Monetary Penalties Law (“CMP Law”). In addition, the Opinion follows other recent guidance and regulations promulgated by OIG and the Centers for ...
Blog Editors
Recent Updates
- OIG Limits Sign-On Bonuses to In-Home Family Caregivers
- Governing Health AI Development and Adoption: Insights from HHS’s Recently Announced Strategy to Promote AI in Healthcare
- Stranger Things: New FDA Updates Flip Expectations for the Med Tech Industry in 2026 Upside Down
- The DOJ’s Bulk Sensitive Data Rule and Your Obligation to “Know Your Vendor”
- ACCESS Model: CMMI’s New Technology-Enabled Chronic Care Model