Photo of Wendy P. Wright

Wendy focuses her practice on the healthcare industry. She regularly advises clients on compliance with federal and state healthcare laws, including the federal Anti-Kickback Statute and Stark Law, Medicare coverage and payment rules, and state licensure rules.

On April 30, 2019, the United States Department of Health and Human Services (HHS) published a notice of enforcement discretion that lowers most of the annual caps on civil money penalties (CMP). HHS may assess against Covered Entities and Business Associates for violating the Health Insurance Portability and Accountability Act of 1996, as amended (HIPAA).  Specifically, HHS will apply a different cumulative annual CMP limit for each of the four penalty tiers that progressively increases from the first to the fourth penalty tier and maxes out at $1.5 million per violation per year.
Continue Reading HHS Lowers Annual Caps on Most HIPAA CMPs