Posts from 2022
CDC Updates Guidance on Opioid Prescriptions

In a shift from prior policy, the Centers for Disease Control and Prevention (CDC) proposed on February 22, 2022, new guidelines for prescribing opioid painkillers. The new guidance largely avoids figures on dosage strength and length of prescription and warns against abruptly or rapidly discontinuing pain pills for chronic pain patients. It directs physicians to individualize the process and use their best judgement in determining whether to prescribe opioids, and when they do, to start with the lowest effective dosage. The proposed guidelines encourage physicians to weigh ...

Posted in Managed Care
DMHC and DHCS Fine L.A. Care $55 Million in Enforcement Actions

The California Department of Managed Health Care (DMHC) on March 4, 2022, assessed the largest penalty against a health plan in the Department’s history. DMHC and the California Department of Health Care Services (DHCS) jointly announced the results of enforcement actions against Local Initiative Health Authority for Los Angeles County, more commonly known as L.A. Care. The penalties assessed by DMHC and DHCS against L.A. Care include $55 million in fines, which consist of a $35 million fine from DMHC and a $20 million sanction from DHCS. The amount is by far the largest penalty ...

Posted in Managed Care
Understanding the HHS 2023 Proposed Rule

The Department of Health and Human Services (HHS) released its Notice of Benefit and Payment Parameters for the 2023 Proposed Rule on January 5, 2022. Generally, the proposed rule aims to bolster the regulatory framework supporting the marketplace and expand access to health insurance coverage options. 

Posted in Managed Care
Don’t Forget the “PC” in the “Friendly PC” Model

As private equity firms, health systems and entrepreneurs in the medical delivery space seek to gain a level of control over physician practices, many choose to operate under the “Friendly PC” model, especially as many states place restrictions on the corporate practice of medicine.  Under this model, the professional corporation employs the physicians and the non-clinical assets are owned by the health system or private equity firm or related management company, which also employs the non-clinical employees. That management company then has an agreement with the Friendly ...

Posted in Managed Care
California Begins to Question the “Friendly PC” Model

Bill SB 642 is currently under consideration by the California State Legislature and would, if enacted, severely restrict use of the Stock Restriction Agreement and similar arrangements used in the “Friendly PC” model. It would also require significant restructuring of arrangements that use this model for physician integration or practice acquisition in California. During the first legislative session of 2021 2022, SB 642 was passed by the three committees in the California State Senate that considered the bill, and it was placed on the suspension calendar for ...

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