HIPAA Enforcement – The Gathering Storm Has Arrived

Posted by Gregory Fliszar on October 16, 2012
HIPAA, HITECH, Medicaid, Medicare / No Comments

Since the Health Insurance Portability and Accountability Act (“HIPAA”) privacy rules became effective in April 2003, there has been minimal enforcement activity by the U.S. Department of Health and Human Services (“HHS”) Office of Civil Rights (“OCR”).   However, this has changed dramatically over the last two years, as evidenced by some recent high-profile and high-penalty enforcement actions taken by OCR.  In addition to being concerned about OCR investigations, moreover, covered entities and business associates must also be on the alert for enforcement actions by state Attorney Generals, potential class action lawsuits, and OCR’s HIPAA audit program. Continue reading…

Gregory Fliszar

Gregory Fliszar

Gregory M. Fliszar is a member in the Business Law Department and resides in the firm’s Philadelphia office. He recently returned to Cozen O'Connor after briefly serving as Associate General Counsel to Universal Health Services. Greg focuses his practice on health law and handles a variety of health law litigation and regulatory and compliance matters for a number of different types of health care providers including hospitals, hospices, mental health providers, and physician groups. He has significant experience with HIPAA and privacy issues and has counseled insurance company clients on understanding their obligations under the Medicare Secondary Payer Act. He has written and spoken about a number of health law issues including HIPAA and privacy/confidentiality issues as well as the Medicare Secondary Payer Act.

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Reading the Tea Leaves in Regard to the Medicare Secondary Payer Act and Future Medicals

Posted by Gregory Fliszar on July 16, 2012
Medicare / No Comments

On June 14, 2012, the Centers for Medicare & Medicaid Services (“CMS”) released an Advance Notice of Proposed Rulemaking (the “Proposed Rule”) soliciting comments on a proposal to clarify how Medicare beneficiaries and their representatives can protect Medicare’s interests and satisfy their obligations under the Medicare Secondary Payer (“MSP”) Act when “future medical care” is claimed or the settlement, judgment, award, or other payment releases claims for future medical care. Continue reading…

Gregory Fliszar

Gregory Fliszar

Gregory M. Fliszar is a member in the Business Law Department and resides in the firm’s Philadelphia office. He recently returned to Cozen O'Connor after briefly serving as Associate General Counsel to Universal Health Services. Greg focuses his practice on health law and handles a variety of health law litigation and regulatory and compliance matters for a number of different types of health care providers including hospitals, hospices, mental health providers, and physician groups. He has significant experience with HIPAA and privacy issues and has counseled insurance company clients on understanding their obligations under the Medicare Secondary Payer Act. He has written and spoken about a number of health law issues including HIPAA and privacy/confidentiality issues as well as the Medicare Secondary Payer Act.

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