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CMS Confirms Hospitals May Not Bill Secondary Payor Insurers For Amounts In Excess Of Medicare Coinsurance And Deductible Amounts

Client Alert | less than 1 min read | 10.04.11

CMS has re-affirmed earlier 2004 guidance that hospitals participating in the Medicare program may not, where Medicare is primary, bill secondary payor insurers for amounts in excess of applicable Medicare coinsurance and deductible amounts, regardless of the terms of hospital contracts with the payors.


Insights

Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....