Red Flags Rule: The FTC piles on, because HIPAA, ARRA and overlapping state laws just weren't enough

Update 5/28/10:  Red Flags? Nah … nothin' but blue skies.  The FTC delays implementation of the Red Flags Rule yet again, to December 31. Update 11/3/09:  The FTC announced that implementation of the Red Flags Rule will be delayed once more, this time until June 1, 2010.  The announcement came on the heels of losing […]

Grand Rounds Vol. 5, No. 37: The June Is Bustin' Out All Over Edition

June is bustin' out all over . . . .  Lord knows my nose knows it, thanks to all the pollen in the air these days.  Check out the classic movie rendition of this set piece (well worth the eight-minute investment), let your coffee and/or antihistamines kick in, and then let's dive into the past […]

David Harlow quoted in Medicare Compliance Alert on pre-employment background checks

Take some advice from the HealthBlawger in screening new employees.  Check out some specifics in the current edition of DecisionHealth's Medicare Compliance Alert, offered in point-counterpoint format with tips from my friend Bill Mandell. David HarlowThe Harlow Group LLCHealth Care Law and Consulting

No ambulance diversion rule takes effect in Massachusetts

Massachusetts' no diversion rule took effect today.  This is a change long prepared for, but not likely felt immediately in area hospitals — after all, New Year's Day is not a big day for elective surgeries and hospital discharges, and some of the key changes needed in hospitals in order to accommodate the new rule […]

Swapping arrangements, other issues, addressed in OIG supplemental compliance program guidance for nursing facilities

A recurring issue I see in my practice, regarding nursing facility contracts with suppliers and providers (e.g. clinical labs and ambulance services), has been addressed yet again by the OIG.  This time, it's in the OIG Supplemental Compliance Program Guidance for Nursing Facilities published on September 30 (supplementing prior guidance issued in 2000.  The issue […]