Not So Fast – Covering Yourself Up with Stark Blanket Waivers

On March 30, 2020, the Secretary of Health and Human Services issued 18 “Blanket Waivers” protecting specifically described arrangements from sanctions under the federal physician self-referral prohibition (“Stark”) during the COVID-19 national emergency. For an arrangement to take advantage of a Blanket Waiver: (1) the remuneration must be direct (i.e., between entity and physician/physician organization/immediate […]

Read More

123s of Business Assessments

We are all familiar with New Year’s resolutions. At the end of each year, we conduct a self-assessment and set goals for ourselves heading into the new year. Slowly (or in some cases the first day) we drift away from those goals only to rinse and repeat at the end of the year. Similarly, businesses […]

Read More

Alert: Update to Texas Privacy Breach Notification Law

Target. Equifax. Facebook. Capital One.  For us, a data breach is a reminder that the sensitive information we routinely entrust to organizations has inherent value and can be subject to nefarious attacks.  For organizations, it is a reminder of the great responsibility accepted because of the great power received from valuable information.  For states across […]

Read More

Courtney Cowan and Sam Pondrom Speaking at the American Academy of Facial Plastic and Reconstructive Surgery Annual Meeting in San Diego

Courtney Cowan and Sam Pondrom are in San Diego, CA speaking at the American Academy of Facial Plastic and Reconstructive Surgery Annual Meeting. As part of the OFPSA Program, Courtney presented “Utilizing Non-Physician Providers: Who Can Do What?” on Thursday, October 3, 2019.  The following day, Friday, October 4, 2019, Sam presented “Who Can Do […]

Read More

Alex Thiersch and Renee Coover to Speak at AmSpa Boot Camp in New York

Alex R. Thiersch and Renee E. Coover will present at the AmSpa Boot Camp in New York, New York on October 12-13, 2019. The boot camp covers important legal considerations anyone opening or running a medical spa should understand. The presentation, entitled “The Law,” will cover topics including an overview of rules and regulations affecting […]

Read More

Fraud and Abuse Crackdown Continues in Oklahoma and Florida

In addition to the bright sun being so prevalent during these warm summer months, the fraud and abuse enforcement spotlight shines bright on Oklahoma and Florida. In Oklahoma, two cases were filed involving a total of three physicians and five marketers, who were all charged with anti-kickback violations involving compounded prescription drugs.  In one case, […]

Read More