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In his book, The Catcher in the Rye, J.D. Salinger said, “Certain things, they should stay the way they are. You ought to be able to stick them in one of those big glass cases and just leave them alone.”
With the growing emergence of ever-changing and complex rules and regulations applicable to group health and welfare plans, the government is, understandably, reviewing health and group plans for various compliance issues at an increasingly frequent rate.
The Health Insurance Portability and Accountability Act (“HIPAA”) Omnibus Rule1 made significant changes to the HIPAA Privacy, Security, Enforcement and Breach Notification Rules.
In a series of events that read somewhat like a tabloid article gone bad, in March 2011, Excela Health Westmoreland Hospital (“Hospital”) in Pennsylvania sent letters to 141 of its patients informing them that they “may have received” coronary stents that were medically unnecessary.
In the healthcare industry, payors and providers often have claims for both underpayment and overpayment arising from ongoing contracts or other healthcare services rendered.