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Anahita (Ana) Anvari is an associate in the Corporate Practice Group in the firm's Century City office and is a member of the firm’s healthcare practice team.

On March 24, 2023, the Office of Inspector General (“OIG”) issued Advisory Opinion 23-03 (the “Opinion”), in which it decided not to impose sanctions on an Arrangement to provide prepaid gift cards to patients for certain preventative screening tests (the “Arrangement”).

Continue Reading New OIG Opinion Permits Gift Cards to Beneficiaries in Limited Circumstances

Regulatory enforcement and large litigation relating to the use of third party trackers on companies’ websites and applications have been on the rise. Tracking often occurs without the companies’ knowledge or consent. Third party tracking on hospital and provider websites has specifically garnered notable media attention. Recently, there has been significant activity by the Federal Trade Commission (“FTC”) under the Health Breach Notification Rule for unauthorized sharing of personal information. It has begun to penalize and impose steep corrective actions, including long-impacting future restrictions, for such violations.

Continue Reading Web Tracking Creates a Web of Data Privacy Risks

The Centers for Medicare & Medicaid Services (CMS) Innovation Center continues to move forward with its “strategic refresh” initiative. CMS’s strategic refresh initiative aims to meet five objectives: drive accountable care, advance health equity, support care innovations, improve access and affordability, and establish partnerships to achieve these objectives.

Continue Reading CMS Announces Strategy on Value-Based Payments for Specialty Care

In its December Hospital Flash Report, Kaufman Hall identified and reviewed the continued, negative impact of COVID-19 on hospital operating margins. After a dramatic drop in hospital margins during the height of the pandemic in 2020 and early 2021, hospitals experienced a fluctuation of decreasing and increasing margins in the latter-half of the year. Overall, hospital margins remain significantly narrower than they were in 2019, before the pandemic. As a result, the industry may see an increase in hospital transactions in 2022 to offset the operational and financial hardships that continue to burden the health care system, as described in greater detail below.

Continue Reading COVID-19 Impacts and Outcomes on Hospital Margins in 2021: Increased Activity in Hospital Transactions in 2022?