Andrew Wachler


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HIPAA Privacy and Security Enforcement: Assessing and Reducing Risks

As of April 14, 2003, covered entities are expected to be in compliance with the HIPAA Privacy Rule and the April 21, 2005 deadline for Security is rapidly approaching. Health care providers and their attorneys are now left wondering where the liability risks lie and how to best mitigate these risks. Governmental Enforcement of the Privacy Rule The Interim Final Enforcement Rule... (posted by Andrew 2 years 218 days ago.)
Does Your Practice Qualify as a Group Practice Under Federal Stark Law

The Federal Stark law prohibits physicians from referring Medicare/Medicaid beneficiaries to an entity in which they (or an immediate family member) have a financial relationship for designated health services ("DHS"), unless an exception applies. DHS include: clinical lab; physical therapy; occupational therapy; radiology (including, MRI, CAT scans, and ultrasounds); radiation... (posted by Andrew 2 years 218 days ago.)
Stark II Phase II Is Here Have You Analyzed Your Health Care Clients Financial Relationships?

Introduction When structuring many common business relationships involving health care providers, attorneys must be aware of the myriad of Federal and State laws that may be implicated as a result of the arrangement. The health care industry is heavily regulated with laws governing practices that may be entirely legal in other industries, but are... (posted by Andrew 2 years 218 days ago.)
New Stark Rules Yet More Arrangements to be Restructured

On August 19, 2008, the Centers for Medicare and Medicaid Services ("CMS") published final Stark rules in its 2009 Final Hospital Inpatient Prospective Payment Systems rule ("Final Rule"). The Final Rule contains several important revisions to the Stark regulations, some of which will require physicians, hospitals, or other healthcare providers, to unwind or restructure their arrangements. Some of... (posted by Andrew 2 years 218 days ago.)
Be There Or Pay Up: Developing a Patient No-Show Policy for Your Practice

"No-show" patients are a part of any medical practice. Over the years, physicians and other practitioners have developed numerous policies in an attempt to prevent no-shows. Most practices institute such policies as a deterrent rather than for the purpose of actually collecting additional fees since collections efforts can be more expensive then the fees collected. Some... (posted by Andrew 2 years 218 days ago.)
Stark II Phase III

The long-awaited third and final phase of the rulemaking that amends the Stark regulations (Stark) was released by the Centers for Medicare and Medicaid Services (CMS) on August 27, 2007. The phase III final rule (Phase III) will be effective December 4, 2007. Although CMS states that Phase III is flexible and favorable to the health care industry, Phase III is not the last piece of the puzzle addressing changes to Stark. That is... (posted by Andrew 2 years 218 days ago.)