Articles and Blogs

The Department of Health and Human Services (“HHS”) updated its Provider Relief Fund Frequently Asked Questions (“FAQs”). The latest revisions are dated May 26 and 29, 2020 and June 2, 2020 and include new FAQs and modifications to existing FAQs. A Hall Render alert on those revisions and updates is here. HHS added FAQs... READ MORE

On May 21, 2020, Hall Render published “Providers Beware: Avoiding the Pitfalls in Regulatory Flexibilities and Relief Funds.” On May 26, 2020, OIG published “OIG Strategic Plan: Oversight of COVID-19 Response and Recovery.” To those who follow health care compliance and enforcement issues closely, the OIG document should come as no surprise. Over the... READ MORE

Tuesday, June 2 Update Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. Going forward, these updates will be distributed as developments warrant instead of nightly. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. Note – ​we believe this is... READ MORE

As expected COVID-19 related litigation steadily increases, a lawsuit recently filed in the Northern District of Indiana presents a novel approach regarding the potential applicability of the Families First Coronavirus Response Act (the “FFCRA”) to large employers who are otherwise not covered under the FFCRA. The employer, with more than 500 employees, was not... READ MORE

As Shelter-in-Place Orders are relaxed, employers are able to resume varying degrees of pre‑COVID‑19 operations subject to a myriad of state, county and sometimes city government recommendations and/or requirements. However, covered employers remain subject to the Emergency Paid Sick Leave Act (“EPSLA”) and the Emergency Family and Medical Leave Expansion Act (“EFMLA”). Both of... READ MORE

In a March 20, 2020 letter to HHS Secretary Azar, 340B Health, a membership organization consisting of more than 1,400 nonprofit hospitals in the 340B drug pricing program, advised the Secretary that its member hospitals fear the COVID-19 public health emergency could have a “material impact” on hospital admissions and payor mix, which, in... READ MORE

Teaching hospitals, teaching physicians and other providers will have additional flexibility to respond to the COVID‑19 public health emergency (“PHE”) under an interim final rule with comment period (“Rule”) that CMS published on May 8, 2020. The Rule should work to stabilize teaching hospitals’ graduate medical education (“GME”) payments during the COVID‑19 PHE, and... READ MORE

Thursday, May 28 Update Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. Going forward, these updates will be distributed as developments warrant instead of nightly. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. Note – ​we believe this is... READ MORE

On May 26, 2020, OIG released its Strategic Plan for Oversight of COVID-19 Response and Recovery (“Strategic Plan”). The Strategic Plan lays out OIG’s priorities for ensuring that HHS’s COVID-19 relief funds are appropriately disbursed and used, and it gives insights into the enforcement activities that relief fund recipients can expect to see going... READ MORE

Tuesday, May 26 Update Our Federal Advocacy Team is dedicated to providing frequent COVID-19 updates as they develop. Going forward, these updates will be distributed as developments warrant instead of nightly. These updates along with other resources can be found ​on the COVID-19 ​Resource ​Center page ​of Hall Render’s website​. Note – ​we believe this is... READ MORE