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HHS Clarifies NPDB Reporting Obligations

Client Alert | 1 min read | 09.24.03

Some health care entities have expressed concern that the National Practitioner Data Bank regulations require health care entities to report adverse actions taken against practitioners to both the NPDB and the applicable State Board of Medical Examiners, while the NPDB Guidebook directs health care entities to report directly to the NPDB first, and then subsequently to send to the State Board the Report Verification Document that the NPDB sends to the plan confirming receipt of the adverse action report in satisfaction of the plan's Board reporting obligation. We requested confirmation of health care entity obligations from the NPDB, and received the attached letter from HRSA Deputy Administrator Cynthia Grubbs in response. The letter confirms the process set forth in the Guidebook, and should provide additional comfort to health care entities who may have been unsure of their obligations.

Insights

Client Alert | 2 min read | 02.28.25

FinCEN Pauses Fines and Penalties for Non-Compliance with Beneficial Ownership Information Reporting Deadlines

We previously reported that the Corporate Transparency Act’s Beneficial Ownership Information Reporting Rule (BOI Rule) was back in effect as of February 18, 2025, with a stay of the final nationwide block to enforcement. At that time, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extended the BOI Rule’s reporting deadline until March 21, 2025 (in cases where the originally-applicable deadline had expired) for entities required to report, which includes certain entities formed or registered to do business in the United States (Reporting Companies). ...