Category: Blogs

The No Surprises Act (NSA), effective January 1, 2022, generally protects patients from receiving unanticipated bills for emergency care rendered by providers who do not participate with the patient’s insurance coverage (out-of-network providers), and includes a prohibition on certain out-of-network providers balance billing patients. The law also requires that the patient’s insurer reimburse the out-of-network…Read More

In the first major update in fifteen years, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently released new voluntary compliance program guidelines (CPGs) for health care companies aimed at preventing fraud and waste in the health care system.  Last spring, the OIG announced plans to update and to…Read More

In March 2023, approximately 100 physicians at a Minneapolis hospital owned by Allina Health voted to unionize. Just seven months later, over 400 primary care physicians employed in clinics owned by the same health system also voted to join the Doctors Council of the Service Employees International Union.   This recent push to unionize is…Read More

Amidst the financial complexities and risks facing the healthcare sector, from inflation and outdated contracts to workforce shortages and diminishing market share, healthcare organizations are navigating a challenging landscape. Effective mitigation strategies include service line assessments, workforce prioritization, leveraging patient feedback, outsourcing non-clinical tasks, and seeking strategic collaborations. These measures are vital for enhancing financial…Read More

This is the second part of a several part series of articles pertaining to limited liability company operating agreements. This second installment addresses voting rights, distributions, capital accounts, buy-ins and buy-outs. Many medical practices and other health care enterprises operate as limited liability companies (LLCs), and are, therefore, governed by the LLC’s “operating agreement.” However,…Read More

Recently, the U.S. Department of Justice (DOJ) and Federal Trade Commission (FTC) released Draft Merger Guidelines (Draft Guidelines) outlining various new factors the Agencies will consider when reviewing the legality of mergers and acquisitions.   The Draft Guidelines set forth 13 new frameworks that the Agencies will use to determine whether a merger violates antitrust…Read More

On February 13, 2023, the Department of Health and Human Services (HHS) proposed a new rule that would require most nursing homes to provide detailed information about facility owners, operators, and management teams, including clinical consulting and administrative services. The Rationale The proposed rule would implement the reporting requirements initially created by Section 6101(a) of…Read More

IV hydration businesses are popping up in major cities across the country, including here in Maryland. Most hydration businesses offer a variety of products to their customers, including infusions of vitamins and other elements promoted to improve health or reduce stress. Since these businesses are relatively new, they remain largely unregulated.  However, recent guidance from…Read More

In October 2023, the Maryland Health Care Commission (MHCC or Commission) reviewed and approved for public comment Proposed Final Regulations making significant changes to the Procedural Regulations for Health Care Facilities and Services. This is the latest step in a multi-year process of updating the certificate of need (CON) regulations to conform with significant statutory…Read More