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Many colleges and universities offer on-campus healthcare clinic services to their students. These student health clinics are typically staffed by a physician or advanced practice provider such as a nurse practitioner. In addition to providing professional services, these providers may on occasion prescribe medications to students. Some of our clients have asked whether it is also permissible for the providers to actually dispense these medications on-site, even though the clinic is not licensed as a pharmacy.
Continue Reading Dispensing Medications at Student Health Clinics

COVID-19 has affected all aspects of hospice care, operations and personnel, including the person whose judgment is at the center of the Medicare hospice benefit: the hospice physician. In this episode of Hospice Insights, we discuss the increased significance of, and scrutiny applied to, hospice physicians in the age of COVID-19, and identify potential traps

Updated April 3, 2020

In response to the growing Coronavirus pandemic, the Small Business Administration (“SBA”) will make loans available to businesses that employ fewer than 500 people (and in certain instances a larger number of employees) through the new Paycheck Protection Program (“PPP”). In this post we address some of the most frequently-asked questions about the PPP, and how eligible healthcare entities can apply.
Continue Reading The Time to Act is Now: Small Business Administration Loans to Healthcare Organizations

Under Texas law, physicians that will be called upon to complete and sign a death certificate in Texas are required to register to file the certificate electronically with the Texas Department of State Health Services. The Texas Medical Board is authorized to take action against providers who do not register for electronic filing of death certificates under Tex. Health and Safety Code §193.005. Until recently, registration and filing of death certificates was made through the Texas Electronic Registrar (“TER”).

On January 1, 2019, the Texas Department of State Health Services replaced TER with a new platform, the Texas Electronic Vital Events Registrar (“TxEver”). TxEver supports all vital events operations, including reporting, registration, and amendments of birth and death records, and represents one of the first fully integrated vital records systems nationwide. TxEver will additionally support the Texas remote birth issuance system, which allows users to obtain copies of birth certificates without having to visit the vital records offices in their county of birth.
Continue Reading New fully integrated record system, TxEver replaces Texas Electronic Death Registrar

Beginning on June 1, 2017, health care providers of services and suppliers must submit all information necessary for the Centers for Medicare and Medicaid Services (“CMS”) to analyze actual or potential violations of the federal physician self-referral law (the “Stark Law”) using approved forms designed to streamline the CMS Voluntary Self-Referral Disclosure Protocol (the “SRDP”).  If you are currently working on a self-disclosure filing for CMS, you must convert that disclosure to this new format or risk CMS rejecting the disclosure in its entirety. The new forms, contained within Form CMS-10328 available here, must be used for all voluntary Stark Law self-disclosures submitted on or after June 1, 2017, except disclosures by physician-owned hospitals and rural providers regarding a failure to disclose physician ownership on the provider’s website or in any public advertisement.[1]
Continue Reading Revised SRDP Process Begins June 1

Since the first managed care plans were introduced, relationships between physicians and payers have been rocky. It has not been uncommon for controversies between the two sides to result in lawsuits, contract terminations and regulatory intervention. Both sides recognize that each needs the other to survive — payers must populate their networks with sizeable numbers of physicians, while physicians must contract with payers to get reimbursed for patient care.

Continue Reading Improving Physicians’ Negotiation Skills

On June 9, 2016, the Texas Medical Board proposed for comment new rules regarding physician call coverage. The proposed new rule originated from the Board’s Telemedicine Committee and changes the current telemedicine call coverage rule. The rule would apply to all physician call coverage relationships, not just telemedicine.

During the meetings last week, the Board’s Executive Director stated that the proposed rule was created at the request of the Texas Medical Association and leadership from Children’s Medical Center of Dallas with input from the Texas e-Health Alliance. An earlier draft was withdrawn during the Board’s March 2016 meeting. The current draft was reviewed and discussed during a recent meeting of the Board’s telemedicine stakeholder group.
Continue Reading Texas Medical Board Proposes New Call Coverage Rules for Telemedicine and Traditional Patient Care