On November 1, 2022, the Centers for Medicare & Medicaid (CMS) under the United States Department of Health and Human Services (HHS) finalized changes that are projected to significantly expand access to behavioral health care services, among other things. CMS released a Behavioral Health Strategy in 2022, which included improving access to and quality of …
Michigan Medical Spas: Is the Wild West No More?
There’s a new sheriff in town, and they are looking to crack down on medical spas in Michigan. Medical spas offering minimally invasive cosmetic medical services have enjoyed increasing popularity in the State of Michigan and across the United States. But with great success comes greater scrutiny of the so-called “Wild West” of the healthcare …
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A New Interstate Compact Is in Town: The Interstate Compact for Counselor Licensure.
One interstate compact you may not have heard of yet that could be very helpful for the behavioral health field is the Interstate Compact for Counselor Licensure. As of August 4, 2022, the Counselor Compact now has 17 members – Alabama, Colorado, Delaware, Florida, Georgia (the first state to enact the Counseling Compact), Kentucky, Louisiana, …
Telehealth Update: Telehealth Waivers Post-PHE and Fraud and Abuse
The current Public Health Emergency expiration deadline is this month. However, the Secretary of the Health and Human Services indicated he would provide a 60-day notice before ending the PHE in order to minimize disruptions and potential loss of government and private insurance coverage. That notice has not yet occurred. Therefore, we expect another 90 …
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Reproductive Healthcare Issues for Employers Series, Part 4: Navigating Mental Health Parity Requirements for Travel Benefits
On June 24, 2022, the United States Supreme Court released Dobbs v. Jackson Women’s Health Organization, overturning Roe v. Wade. The Dobbs decision has employers scrambling to understand the impact on group health plan coverage. Many employers are considering implementing travel reimbursement options to assist employees who wish to seek abortions that might be restricted …
White House issues recommendations on telehealth and SUD services – Part II
On June 22, 2022, via the Legislative Analysis and Public Policy Association, the White House Office of National Drug Control Policy (ONDCP) released its “Telehealth and Substance Use Disorder Services in the Era of COVID-19: Review and Recommendations” (Guidance). While this publication does not have the force of law, it is clear direction to legislators …
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Immigration Healthcare Cures for Physicians – A Quixotic Venture?
On February 12, 2022, the Subcommittee on Immigration and Citizenship of the House Committee on the Judiciary held a very informative hearing regarding the relevance of foreign physicians in the healthcare system of the United States (U.S.). The hearing was titled, “Is There a Doctor in the House? The Role of Immigrant Physicians in the …
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White House Issues Recommendations on Telehealth and SUD services
In June 2022, the White House Office of National Drug Control Policy (ONDCP), via the Legislative Analysis and Public Policy Association, released its “Telehealth and Substance Use Disorder Services in the Era of COVID-19: Review and Recommendations” (the “SUD Recommendations”). Although this publication does not have the force of law, it provides clear directions to …
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Post-Pandemic HIPAA Guidelines for Audio-Only Telehealth
The Department of Health and Human Services (“HHS”) recently announced guidelines for the application of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) to audio-only telehealth encounters following the end of the declaration of the COVID-19 public health emergency (“PHE”). As reported here at the beginning of the Covid-19 pandemic, the HHS Office …
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Continued IRS Attack On ‘Zero Out’ Of Profits
A prior article in this publication (IRS Attack on Zeroed Out Taxable Income in Recent Tax Court Cases) discussed the lessons that physician and other incorporated medical practice groups could learn from taxpayer losses in two then recent Tax Court cases in use of the “zero out” technique in the payment of compensation to the …
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