RealMed: Analyzed requirements, defined the solutions architecture, and designed and developed plugins integrated with Centricity for electronic processing / management
of health care transactions, besides deployment at client sites.
Tom Dowdell is a partner in the Washington, D.C. office and a member
of the health care transactions practice group.
The tax consequences
of health care transactions are an important part of business decision - making.
Thus, any element
of a health care transaction that would implicate more than one state's law would automatically preclude the Secretary's evaluation as to whether the laws were more or less stringent than the federal requirement.
Not exact matches
The Advisory Board acquisition was one
of three
transactions the
health insurer made this year, including a $ 2.3 billion deal for Surgical
Care Affiliates, and a $ 2.8 billion deal for Chilean insurer Banmedica.
Such risks and uncertainties include, but are not limited to: our ability to achieve our financial, strategic and operational plans or initiatives; our ability to predict and manage medical costs and price effectively and develop and maintain good relationships with physicians, hospitals and other
health care providers; the impact
of modifications to our operations and processes; our ability to identify potential strategic acquisitions or
transactions and realize the expected benefits
of such
transactions, including with respect to the Merger; the substantial level
of government regulation over our business and the potential effects
of new laws or regulations or changes in existing laws or regulations; the outcome
of litigation, regulatory audits, investigations, actions and / or guaranty fund assessments; uncertainties surrounding participation in government - sponsored programs such as Medicare; the effectiveness and security
of our information technology and other business systems; unfavorable industry, economic or political conditions, including foreign currency movements; acts
of war, terrorism, natural disasters or pandemics; our ability to obtain shareholder or regulatory approvals required for the Merger or the requirement to accept conditions that could reduce the anticipated benefits
of the Merger as a condition to obtaining regulatory approvals; a longer time than anticipated to consummate the proposed Merger; problems regarding the successful integration
of the businesses
of Express Scripts and Cigna; unexpected costs regarding the proposed Merger; diversion
of management's attention from ongoing business operations and opportunities during the pendency
of the Merger; potential litigation associated with the proposed Merger; the ability to retain key personnel; the availability
of financing, including relating to the proposed Merger; effects on the businesses as a result
of uncertainty surrounding the proposed Merger; as well as more specific risks and uncertainties discussed in our most recent report on Form 10 - K and subsequent reports on Forms 10 - Q and 8 - K available on the Investor Relations section
of www.cigna.com as well as on Express Scripts» most recent report on Form 10 - K and subsequent reports on Forms 10 - Q and 8 - K available on the Investor Relations section
of www.express-scripts.com.
Since 2014, KKR has executed a number
of transactions as part
of the firm's
health care growth equity strategy.
In one
of the largest
transactions of the year, CVS
Health said it had agreed to buy Aetna for about $ 69 billion in a deal that would combine the drugstore giant with one of the biggest health insurers in the United States and has the potential to reshape the nation's health care ind
Health said it had agreed to buy Aetna for about $ 69 billion in a deal that would combine the drugstore giant with one
of the biggest
health insurers in the United States and has the potential to reshape the nation's health care ind
health insurers in the United States and has the potential to reshape the nation's
health care ind
health care industry.
When the
transaction is finalized, Ingalls will join UChicago Medicine's
health network that includes the main medical campus in Hyde Park, numerous outpatient facilities including the planned Centers for Advanced
Care in Orland Park and in the South Loop, as well as the University
of Chicago Medicine
Care Network
of physicians.
Worldwide About Blog Providing fresh insight and analysis into the ever - changing landscape
of health care law.Health Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and health care transaction legal issues Frequency about 1 post per w
care law.
Health Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and health care transaction legal issues Frequency about 1 post per w
Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and
health care transaction legal issues Frequency about 1 post per w
care transaction legal issues Frequency about 1 post per week.
Worldwide About Blog Providing fresh insight and analysis into the ever - changing landscape
of health care law.Health Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and health care transaction legal issues Frequency about 1 post per w
care law.
Health Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and health care transaction legal issues Frequency about 1 post per w
Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and
health care transaction legal issues Frequency about 1 post per w
care transaction legal issues Frequency about 1 post per week.
Angie's List helps facilitate happy
transactions between more than three million consumers nationwide and its collection
of highly rated service providers in more than 720 categories
of service, ranging from home improvement to
health care.
Worldwide About Blog Providing fresh insight and analysis into the ever - changing landscape
of health care law.Health Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and health care transaction legal issues Frequency about 1 post per w
care law.
Health Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and health care transaction legal issues Frequency about 1 post per w
Care news law blog from Foley & Lardner LLP, a leading law firm for medical, hospital, senior living, mHealth, and
health care transaction legal issues Frequency about 1 post per w
care transaction legal issues Frequency about 1 post per week.
«Covered entities» include
health plan providers, healthcare clearinghouses and
health care providers (who conduct a portion
of their business electronically using a HIPAA covered
transaction).
In the last year and a half, Olasker has acted in a number
of transactions including acting as Canadian counsel in the high - profile acquisition
of the Rexall pharmacy chain by U.S. - based
health -
care services provider McKesson Corp..
Notable mandates: Defence
of class actions in the
health -
care sector; acted for the government
of the Northwest Territories in its successful defence at the Supreme Court
of Canada
of a fatality claim arising from the death
of nine miners; represented a large number
of former residential schools victims in their claims; acted for the vendor in a
transaction involving the sale
of 120 rehabilitation and physiotherapy clinics across Canada
Business Development: Brokering various business dealings that further the diversification
of Indian economies Developing and accessing commercial financial programs and services for tribal governments, including tax - exempt offerings and federally - guaranteed housing loans Serving as issuer or underwriter's counsel in tribal bond issuances Ensuring tribal compliance with Bank Secrecy Act and other federal financial regulatory requirements Handling federal and state income, excise, B&O, property and other tax matters for tribes and tribal businesses Chartering tribal business enterprises under tribal, state and federal law Registering and protecting tribal trademarks and copyrights Negotiating franchise agreements for restaurants and retail stores on Indian reservations Custom - tailoring construction contracts for tribes and general contractors Helping secure federal SBA 8 (a) and other contracting preferences for Indian - owned businesses Facilitating contractual relations between tribes and tribal casinos, and gaming vendors Building tribal workers» compensation and self - insurance programs Government Relations: Handling state and federal regulatory matters in the areas
of tribal gaming, environmental and cultural resources, workers» compensation, taxation,
health care and education Negotiating tribal - state gaming compacts and fuel and cigarette compacts, and inter-local land use and law enforcement agreements Advocacy before the Washington State Gambling Commission, Washington Indian Gaming Association and National Indian Gaming Commission Preparing tribal codes and regulations, including tribal court, commercial, gaming, taxation, energy development, environmental and cultural resources protection, labor & employment, and workers» compensation laws Developing employee handbooks, manuals and personnel policies Advocacy in areas
of treaty rights, gaming, jurisdiction, taxation, environmental and cultural resource protection Brokering fee - to - trust and related real estate and jurisdictional
transactions Litigation & Appellate Services: Handling complex Indian law litigation, including commercial, labor & employment, tax, land use, treaty rights, natural and cultural resource matters Litigating tribal trust mismanagement claims against the United States, and evaluating tribal and individual property claims under the Indian Claims Limitation Act Defending tribes and tribal insureds from tort claims brought against them in tribal, state and federal courts, including defense tenders pursuant to the Federal Tort Claims Act Assisting tribal insureds in insurance coverage negotiations, and litigation Representing individual tribal members in tribal and state civil and criminal proceedings, including BIA prosecutions and Indian probate proceedings Assisting tribal governments with tribal, state and federal court appeals, including the preparation
of amicus curiae briefs Our Indian law & gaming attorneys collaborate to publish the quarterly «Indian Legal Advisor ``, designed to provide Indian Country valuable information about legal and political developments affecting tribal rights.
EXPERIENCED
HEALTH CARE ATTORNEY With over twenty years of legal experience, Chris represents and counsels numerous hospitals, health systems, physicians, physician practice groups, and other health care businesses on a variety of legal matters such as: STRATEGIC INITIATIVES: Medical practice transactions and acquisitions; joint ventures; integration strategies and models; corporate formation, affiliation and gover
HEALTH CARE ATTORNEY With over twenty years of legal experience, Chris represents and counsels numerous hospitals, health systems, physicians, physician practice groups, and other health care businesses on a variety of legal matters such as: STRATEGIC INITIATIVES: Medical practice transactions and acquisitions; joint ventures; integration strategies and models; corporate formation, affiliation and governa
CARE ATTORNEY With over twenty years
of legal experience, Chris represents and counsels numerous hospitals,
health systems, physicians, physician practice groups, and other health care businesses on a variety of legal matters such as: STRATEGIC INITIATIVES: Medical practice transactions and acquisitions; joint ventures; integration strategies and models; corporate formation, affiliation and gover
health systems, physicians, physician practice groups, and other
health care businesses on a variety of legal matters such as: STRATEGIC INITIATIVES: Medical practice transactions and acquisitions; joint ventures; integration strategies and models; corporate formation, affiliation and gover
health care businesses on a variety of legal matters such as: STRATEGIC INITIATIVES: Medical practice transactions and acquisitions; joint ventures; integration strategies and models; corporate formation, affiliation and governa
care businesses on a variety
of legal matters such as: STRATEGIC INITIATIVES: Medical practice
transactions and acquisitions; joint ventures; integration strategies and models; corporate formation, affiliation and governance.
Wickouski counsels clients on all aspects
of bankruptcy, insolvency and commercial
transactions, including bond defaults, trust indentures, business acquisitions, real estate,
health care and financial fraud.
Crowley Fleck «s Healthcare practice group daily handles complex matters affecting the healthcare industry involving business
transactions, compliance, healthcare reform,
health information systems, HIPAA, joint ventures, labor and employment, licensing and certificates
of need, managed
care, Medicare and Medicaid matters, medical staff relations, joint ventures, including physician and physician hospital joint ventures, business
transactions, compliance,
health care reform,
health information systems, HIPAA, joint ventures, labor and employment, licensing, managed
care, Medicare and Medicaid payments, medical staff relations, patient
care, real estate and construction, regulatory, risk management, tax, and tax - exempt matters, and tax exempt financing matters.
Mr. Antoun concentrates his practice in the areas
of health care, business and governmental
transactions.
Practitioners must develop an array
of skills that include negotiating mergers and acquisitions; representing clients in federal and state investigations and civil actions; instructing clients on certificate
of need and licensing matters; advising clients on compliance and third - party payor claims such as Medicare and Medicaid; forming and operating
health care corporations and partnerships including provider networks; representing clients in financing and securities
transactions; and litigating a variety
of disputes.
We have represented clients in finance
transactions across the spectrum
of the
health care industry, including device manufacturers, pharmaceutical companies, hospitals, acute and long term
care facilities, drug store chains,
health care staffing companies, and independent physician associations, among others.
He handles matters for clients involving: Medicare and Medicaid program certification, coverage, billing, and payment; hospital, physician, and other provider
transactions; fraud and abuse; compliance; internal and external audits; disclosures and repayments; graduate medical education accreditation and payment; physician and non-physician practitioner scope
of practice, coverage, coding and billing; and federal
health care legislation and rulemaking.
From
health care transactions and regulatory counseling to fraud and abuse investigations, from the defense
of government enforcement actions to political advocacy and lobbying, Bryan Cave provides comprehensive and robust solutions to complicated and challenging
health care matters.
Components that create protected
health information through research would be covered entities to the extent they performed one
of the required
transactions described in § 164.500; however, it is possible that the research program would not be part
of the
health care component, depending on whether the research program performed or supported covered functions.
Comment: A number
of commenters urged the Department to expand or clarify the definition
of «covered entity» to include certain entities other than
health care clearinghouses,
health plans, and
health care providers who conduct standard
transactions.
A department or component
of a
health plan or
health care provider that transforms nonstandard information into standard data elements or standard
transactions (or vice versa) is not a clearinghouse for purposes
of this rule, unless it also performs these functions for another entity.
However, where the downstream
transaction is not conducted on behalf
of the
health care provider, the provider does not become a covered entity due to the downstream
transaction.
We do not consider a financial institution to be acting on behalf
of a covered entity, and therefore no business associate contract is required, when it processes consumer - conducted financial
transactions by debit, credit or other payment card, clears checks, initiates or processes electronic funds transfers, or conducts any other activity that directly facilitates or effects the transfer
of funds for compensation for
health care.
Issuers
of other long - term
care policies are considered to be
health plans under this rule and the
Transactions Rule.
Response: We agree that online companies are covered entities under the rule if they otherwise meet the definition
of health care provider or
health plan and satisfy the other requirements
of the rule, i.e., providers must also transmit
health information in electronic form in connection with a HIPAA
transaction.
HIPAA restricts the type
of entities covered by the rule to three broad categories:
health care providers that transmit
health information in HIPAA standard
transactions,
health plans, and
health care clearinghouses.
This information is always needed to complete a standard
Health Care Payment and Remittance Advice
transaction, but is never needed for the funds transfer activity
of the financial institution.
We proposed in the NPRM to apply the standards in the regulation to
health plans,
health care clearinghouses, and to any
health care provider who transmits
health information in electronic form in connection with
transactions referred to in section 1173 (a)(1)
of the Act.
We adopted the ASC X12N 835
transaction standard for «
Health Care Payment and Remittance Start Printed Page 82496Advice» transactions between health plans and health care providers, and the ASC X12N 820 standard for «Health Plan Premium Payments» transactions between entities that arrange for the provision of health care or provide health care coverage payments and health
Health Care Payment and Remittance Start Printed Page 82496Advice» transactions between health plans and health care providers, and the ASC X12N 820 standard for «Health Plan Premium Payments» transactions between entities that arrange for the provision of health care or provide health care coverage payments and health pl
Care Payment and Remittance Start Printed Page 82496Advice»
transactions between
health plans and health care providers, and the ASC X12N 820 standard for «Health Plan Premium Payments» transactions between entities that arrange for the provision of health care or provide health care coverage payments and health
health plans and
health care providers, and the ASC X12N 820 standard for «Health Plan Premium Payments» transactions between entities that arrange for the provision of health care or provide health care coverage payments and health
health care providers, and the ASC X12N 820 standard for «Health Plan Premium Payments» transactions between entities that arrange for the provision of health care or provide health care coverage payments and health pl
care providers, and the ASC X12N 820 standard for «
Health Plan Premium Payments» transactions between entities that arrange for the provision of health care or provide health care coverage payments and health
Health Plan Premium Payments»
transactions between entities that arrange for the provision
of health care or provide health care coverage payments and health
health care or provide health care coverage payments and health pl
care or provide
health care coverage payments and health
health care coverage payments and health pl
care coverage payments and
health health plans.
Except as otherwise provided, the provisions
of this part apply to covered entities:
health plans,
health care clearinghouses, and
health care providers who transmit
health information in electronic form in connection with any
transaction referred to in section 1173 (a)(1)
of the Act.
Section 1172
of the Act makes the standard adopted under part C applicable to: (1)
Health plans, (2) health care clearinghouses, and (3) health care providers who transmit health information in electronic form in connection with transactions referred to in section 1173 (a)(1) of the Act (hereinafter referred to as the «covered entities&ra
Health plans, (2)
health care clearinghouses, and (3) health care providers who transmit health information in electronic form in connection with transactions referred to in section 1173 (a)(1) of the Act (hereinafter referred to as the «covered entities&ra
health care clearinghouses, and (3)
health care providers who transmit health information in electronic form in connection with transactions referred to in section 1173 (a)(1) of the Act (hereinafter referred to as the «covered entities&ra
health care providers who transmit
health information in electronic form in connection with transactions referred to in section 1173 (a)(1) of the Act (hereinafter referred to as the «covered entities&ra
health information in electronic form in connection with
transactions referred to in section 1173 (a)(1)
of the Act (hereinafter referred to as the «covered entities»).
We note that we do not consider a financial institution to be acting on behalf
of a covered entity, and therefore no business associate contract is required, when it processes consumer - conducted financial
transactions by debit, credit or other payment card, Start Printed Page 82505clears checks, initiates or processes electronic funds transfers, or conducts any other activity that directly facilitates or effects the transfer
of funds for compensation for
health care.
A rule establishing a unique identifier for employers to use in electronic
health care transactions, a rule establishing a unique identifier for providers for such
transactions, and a rule establishing standards for the security
of electronic information systems have been proposed.
However, our jurisdiction under the statute is limited to
health plans,
health care clearinghouses, and
health care providers who transmit any
health information electronically in connection with any
of the standard financial or administrative
transactions in section 1173 (a)
of the Act.
We do not agree, however, that covered entities should be expected to maintain
health information outside
of an electronic system, particularly as
health care providers and
health plans extend their reliance on electronic
transactions.
A
health care provider who is an employee and is administering drug testing on behalf
of the employer, but does not conduct standard
transactions, is not a covered entity.
Another social service worker may provide services that do not meet the rule's definition
of health care, or may not transmit information in a standard
transaction.
We agree that the underlying statutory goal
of standardizing financial and administrative
health care transactions dictates that exceptions should be granted only on narrow grounds.
As noted by the commenters,
health care entities now typically operate in a multi-state environment, so already make the choice
of law judgements that are necessary in multi-state
transactions.
Electronic
transactions have achieved tremendous savings in the
health care system and electronic records have enabled significant improvements in the quality and coordination
of health care.
These are the entities described in section 1172 (a)(1):
Health plans, health care clearinghouses, and health care providers who transmit any health information in electronic form in connection with a transaction referred Start Printed Page 82477to in section 1173 (a)(1) of the Act (a «standard transaction&ra
Health plans,
health care clearinghouses, and health care providers who transmit any health information in electronic form in connection with a transaction referred Start Printed Page 82477to in section 1173 (a)(1) of the Act (a «standard transaction&ra
health care clearinghouses, and
health care providers who transmit any health information in electronic form in connection with a transaction referred Start Printed Page 82477to in section 1173 (a)(1) of the Act (a «standard transaction&ra
health care providers who transmit any
health information in electronic form in connection with a transaction referred Start Printed Page 82477to in section 1173 (a)(1) of the Act (a «standard transaction&ra
health information in electronic form in connection with a
transaction referred Start Printed Page 82477to in section 1173 (a)(1)
of the Act (a «standard
transaction»).
However, consistent with the second recommendation above, the statutory cite for «medical
care» was added to the definition
of «
health plan» in the
Transactions Rule, and thus is reflected in this final rule.
With regard to public
health agencies that are also
health care providers, the
health care provider «component»
of the agency is the covered entity if that component conducts standard
transactions.