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CMS issues regulations implementing the Medicare Improvements to Patients and Providers Act (MIPPA) of 2008

Client Alert | 1 min read | 08.26.11

On August 26, 2011, the Centers for Medicare & Medicaid Services issued regulations implementing MIPPA provisions and finalizing revisions to Medicare Advantage (MA), Medicare Part D, and section 1876 cost plans. The revisions together conform "changes to the MA regulations to implement statutory requirements regarding special needs plans (SNPs), private fee-for-service plans (PFFS), regional preferred provider organizations (RPPO) plans, and Medicare medical savings accounts (MSA) plans, cost-sharing for dual-eligible enrollees in the MA program and prescription drug pricing, coverage, and payment processes in the Part D program, and requirements governing the marketing of Part C and Part D plans." These regulations are set to go into effect 60 days after publication in the Federal Register, which is slated for Sept. 1, 2011.

Since then, the final rule has been issued and is now available on the Public Inspection Desk. The rule finalizes revisions to regulations governing Medicare Advantage (MA), Medicare Part D, including "This final rule will go into effect 60 days after publication in the Federal Register, which is slated for Sept. 1."

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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....