Insights & Resources

Garfunkel Wild’s Stacey L. Gulick, Kathleen M. Brown, and Alison T. Schimel will present the webinar “Starting the Patient Journey: Essential Documentation for Treatment and Payment” on April 16, 2025, from 12:00 PM – 1:00 PM ET.

As part of our “Employment Law – What Employers Need to Know Now” webinar series, Garfunkel Wild’s Marianne Monroy and Andy Zwerling will present the webinar “Managing Social Media Use & Matters of Political Opinions in the Workplace” on April 8, 2025, from 12:30 pm – 1:30 pm (ET).

Following months of uncertainty surrounding the future of the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published an interim final rule (Interim Rule) on March 21, 2025 that removes the requirement for U.S. companies and U.S. persons to submit BOI reports to FinCEN under the CTA.

In March, the New York Department of Health (DOH) published “frequently asked questions” (FAQs) related to the law that requires “health care entities” party to a “material transaction” to report the transaction to the DOH in advance. 

Congress has once again extended certain telehealth flexibilities until September 30, 2025 (which coincides with the end of the Congressional fiscal year).

In a surprising new development that comes just days after a temporary ban on the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements was lifted, the U.S. Department of the Treasury (Treasury Department), Financial Crimes Enforcement Network (FinCEN) announced in a March 2nd press release that it will not enforce the BOI reporting requirements against U.S. citizens and domestic reporting companies.

In the first of seven episodes exploring what makes for an effective compliance program, we discuss the importance of having compliance policies and procedures, and how those policies and procedures serve as the foundation upon which effective compliance programs are built. 

Proposed amendments to the regulations governing the Certificate of Need (CON) process for Article 28 facilities, including general hospitals and nursing homes (the Proposal), were published by the New York State Department of Health (DOH) in the February 26, 2025 New York State Register.

Following nearly a year of legal challenges, the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect, with a current filing deadline of March 21, 2025.

The U.S. Department of Health and Human Services, Office of Inspector General (OIG) posted a favorable Advisory Opinion (25-01) allowing a Pharmaceutical Company (Company) to provide free access to its U.S. Food and Drug Administration (FDA)-approved product (Product) for eligible patients with mild cognitive impairment or disease-related dementia and related symptoms.

The U.S. Department of Health and Human Services, Office of Inspector General (OIG) posted a favorable Advisory Opinion (24-13) allowing a pharmaceutical manufacturer (Manufacturer) to provide transportation, lodging, meal vouchers, and other authorized expenses to eligible patients receiving Manufacturer’s one-time, potentially curative treatment product (Product).

The U.S. Department of Health and Human Services, Office of Inspector General (OIG) posted a favorable Advisory Opinion (24-12) allowing a pharmaceutical manufacturer (Manufacturer) to sponsor a genetic testing, genetic counseling, and disease-state awareness education program for certain eligible patients with an “ultra-rare” genetic condition that causes kidney stones.

The U.S. Department of Health and Human Services, Office of Inspector General (OIG), posted a favorable Advisory Opinion (24-11) allowing a pharmaceutical manufacturer (Manufacturer) to provide free meningococcal vaccinations to eligible patients, including Federal health care program enrollees who receive Manufacturer’s U.S. Food and Drug Administration (FDA)-approved products that treat rare disorders.

The U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG) posted a favorable Advisory Opinion (24-10) allowing the expansion of an existing loyalty program offered by a medical and dental supply distributor (Company) to its member customers (Customers), while cautioning that “discount” programs are typically high risk.

On December 11, 2024, the U.S. Department of Health and Human Services, Office of the Inspector General (OIG) published a Special Fraud Alert in response to the uptick in abusive marketing practices between Medicare Advantage Organizations (MAOs), health care providers, and ancillary participants (such as agents and brokers).

Show your love this February by establishing a comprehensive estate plan that ensures your family is protected and your wishes are honored in the event of your incapacity or death.

Garfunkel Wild will be a sponsor at the eCap Healthcare Summit 2025 in Miami, Florida from February 10-12, 2025.

Garfunkel Wild’s Colleen M. Tarpey participated in a panel discussion at Healthcare Financial Management Association’s Metro NY Chapter Winter 2025 Revenue Cycle Academy event, Friday, February 7, 2025.

On February 4, 2025, the New York State Assembly Health Committee will vote on legislation that proposes to increase the penalties for violations of the State Public Health Law (PHL), with an increased maximum penalty specifically for Article 28 hospitals and nursing homes. The justification for this proposed measure is that current monetary penalties for PHL violations are “outdated” and “nonthreatening” and merely regarded as the “cost of doing business.”

On January 21, 2025, New York Governor Kathy Hochul released the proposed FY 2026 New York State Executive Budget, which includes enhanced scrutiny of material transactions involving health care entities.