Articles and Blogs


Creating Swing Beds: Key Regulatory, Operational, Billing and Compliance Considerations Under the CMS Blanket Waivers


Posted on July 20, 2020 in Compliance

Written by: Hall Render Advisory Services

CMS recently issued an update of a memorandum entitled “COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers” (“Blanket Waiver Memo”) that announced additional blanket waivers for providers, including hospitals and skilled nursing facilities (“SNFs”) as a result of the COVID-19 public health emergency (“PHE”). The waivers have a retroactive effective date of March... READ MORE

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OIG Strategic Plan and Next Steps for Organizations to Prepare


Posted on June 3, 2020 in Compliance

Written by: Hall Render Advisory Services

On May 21, 2020, Hall Render published “Providers Beware: Avoiding the Pitfalls in Regulatory Flexibilities and Relief Funds.” On May 26, 2020, OIG published “OIG Strategic Plan: Oversight of COVID-19 Response and Recovery.” To those who follow health care compliance and enforcement issues closely, the OIG document should come as no surprise. Over the... READ MORE

Rent Abatement & Physician Arrangement Compliance During & After COVID-19


Posted on May 20, 2020 in Compliance, Real Estate

Written by: Hall Render Advisory Services

In a song titled “When the Man Comes Around” Johnny Cash sang that “there’s a man going round, taking names…and he decides who to free and who to blame.” How well hospitals and health systems document their blanket waiver arrangements in response to COVID-19 may dictate whether they are “freed” or “blamed” by CMS... READ MORE

OIG Reports on Hospitals’ Experiences in Managing COVID-19 Crisis


Posted on April 6, 2020 in Compliance

Written by: Hall Render Advisory Services

On April 6, 2020, the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) issued a report summarizing OIG’s interviews with hospital administrators across the country on COVID-19. The interviews, which Hall Render summarized in a previous alert, were conducted between March 23 through March 27 and focused on three... READ MORE