“Cybersecurity is patient safety” and the continued downstream implications for the use of PHI for other unlawful purposes including insurance fraud and predatory practices targeted at minors are significant.
On December 2, 2020, CMS published new provisions and exemptions related to the Stark Law (85 Fed. Reg. 77492) and HHS-OIG published new provisions and safe harbors related to the Anti-Kickback Statute (AKS) (85 Fed. Reg. 77684.