If you track national health care policy developments, you’ve been busy lately. Following weeks of growing declarations from Democrats in support of Medicare for All, US House Speaker Nancy Pelosi tamped down exuberance over any plans to replace the Affordable Care Act (ACA).  Then the US Justice Department spoke up. In a March 25 statement to the Court of Appeals for the Fifth Circuit, Justice Department lawyers said US District Court Judge Reed O’Connor’s ruling…

As provided in the Texas Register on March 22, 2019, the Texas Health and Human Services Commission (“HHSC”) has proposed several amendments to Title 1 of the Texas Administrative Code, which include amendments to the rules and procedures for preventing and investigating Medicaid fraud and abuse.…

After years of insisting that nursing colleges separately incorporate from related hospitals and hospital systems, causing some schools to relinquish Medicare “pass-through” funding,  the Higher Learning Commission (HLC) has changed course. Today, HLC issued a Separate Incorporation Policy Change. Removing language interpreted by prior HLC leadership as requiring separate incorporation, the revised policy substitutes a requirement that HLC-accredited institutions have a “primary purpose” of providing higher education. More specifically, the revised policy (HLC’s “Jurisdiction”…

Recently enacted federal law expanding criminal liability for kickbacks related to all payors, and increased government enforcement activity in behavioral health (see press release), has heightened the importance of clinical due diligence for private equity investors targeting deals and acquisitions in the emerging behavioral health space.  PE firms continue to target behavioral health opportunities as federal and commercial insurance coverage expands for mental health, including substance abuse treatment and telehealth services.  Such commercial…

This year’s National Home Infusion Association (NHIA) conference kicked off with the 2nd Annual Sterile Compounding Forum. The well-attended track provided an overview of the state of sterile compounding, insight into the most common citations confronting sterile compounders, considerations for compliance and risks relating to compounding, background on how states and the FDA are implementing rules and regulations, including those involved in the delivery of home infusion products. We are pleased to sponsor the NHIA …