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Mitigating Risk and Reducing Costs with Smart Healthcare Records Management

Healthcare IT Today

The following is a guest article by Mitchell Perry, VP Compliance & Security at Access In the ever-evolving landscape of healthcare IT in US healthcare frameworks, integrating electronic health records (EHRs) has become a cornerstone for providers. If healthcare providers fail to comply, the consequences can be costly.

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Key Legal Issues Facing Telehealth Platforms, as Compliance Concerns Bubble for Platforms Launched During the Public Health Emergency

Health Care Law Brief

In addition, the PHE fueled a boom in the number of direct-to-consumer (“DTC”) telehealth platforms, many of which have relied upon COVID-19 regulatory waivers to launch and operate in multiple states across the nation. Variety of Risks Present in Telehealth Arrangements. Concerns Proliferate for Telehealth Platforms.

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Episode 23: The Emerging Investigatory Focus on Telehealth: What You Need to Know

Healthcare Law Today

He advises entrepreneurial health care providers and technology companies on business arrangements, compliance, and corporate matters in telemedicine, digital health, remote patient monitoring, and click-and-mortar services. I’m currently Deputy General Counsel of LifeMD, a growing telemedicine company.

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OIG Approves Cash Equivalents Paid to Patients Participating in Contingency Management Program Offered Through Digital Health Technology

Health Care Law Brief

Notwithstanding these streams of remuneration taking the form of cash equivalents and not being protected by an AKS regulatory safe harbor or by an exception to the Beneficiary Inducements CMP, the OIG still concluded that the Arrangement presented a minimal risk of fraud and abuse based on a totality of the underlying facts and circumstances.

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OIG Removes Barrier to Requests for and Issuances of Advisory Opinions When the Same Conduct is Under Investigation

Health Care Law Brief

at 1368 (emphasis added). However, OIG’s sentiment may presume too much. First, OIG appears to presuppose that any conduct under investigation by DOJ—by virtue of it being under investigation—is problematic.

Fraud 52
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OIG Issues Special Fraud Alert Regarding Telemedicine Arrangements

Health Care Law Brief

On July 20, 2022, the Office of Inspector General for the Department of Health and Human Services (“ OIG ”) issued a special fraud alert (“ Alert ”) advising “practitioners to exercise caution when entering into arrangements with purported telemedicine companies.” OIG Flags Seven Characteristics of Telehealth Fraud.

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OIG Publishes Favorable Advisory Opinion Related to the Employment Safe Harbor

Health Care Law Brief

Since at issue was a “straightforward employment agreement” where the employer “assumes certain duties that may be typical of an employer and where … the CRNA is a bona fide employee,” the OIG deemed the employment to present a low risk of abuse and approved the relationship.