In This Issue

Winds of Change Blowing Across the Hospice Landscape – Recent Medicare developments indicate that end-of-life health care providers can expect to face continuing change in an already dynamic sector. These latest turns are part of an ongoing trend toward redefining hospice and end-of-life care in the United States.

D.C. Circuit Resuscitates Elimination of Companionship and Domestic Service Exemptions for Third-Party Employers – The ongoing legal battle over the U.S. Department of Labor (DOL) Final Rule changing the definitions of “companionship services” and live-in domestic employees again turned against employers on August 21, 2015. The US Court of Appeals for the D.C. Circuit issued its decision in Home Care Association of America v. Weil and unanimously reversed a lower court decision holding the DOL exceeded its authority when it issued the Final Rule. The Final Rule was to take effect on January 1, 2015, but enforcement was stayed pending the appeal.

Trends in HIPAA Enforcement Actions
What They Mean for Phase 2 Audit Preparation and Compliance Planning – The Office of Civil Rights (OCR) recently announced plans to begin the next round of its HIPAA audit program in early 2016. In comments responding to two reports issued by the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services on September 29, 2015, OCR announced that it will begin Phase 2 of the HIPAA audits early next year.

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