Caroline Brown

Caroline Brown

Caroline Brown’s practice focuses on government-sponsored health care programs — including Medicaid, Medicare, CHIP, and the Affordable Care Act — with a special emphasis on how the different programs interrelate. Ms. Brown helps her clients navigate and comply with regulatory and statutory provisions that courts have described as “among the most completely impenetrable texts within human experience.” With over 20 years’ experience in the field, the key to Ms. Brown’s success is understanding how those provisions are interpreted and applied by the Centers for Medicare & Medicaid Services (CMS) through subregulatory guidance and uncodified policies and procedures.

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Medicare Advantage Organizations Provided New Opportunities to Offer Telehealth Benefits

Earlier this year, President Trump signed into law the Bipartisan Budget Act of 2018 (BBA), which incorporates provisions from the Creating High-Quality Results and Outcomes Necessary to Improve Chronic (CHRONIC) Care Act of 2017 and improves access to telehealth services in Medicare Advantage. Pub. L. No. 115-123. Among other provisions impacting Medicare Advantage Organizations (MAOs), … Continue Reading

Welcome to Covington eHealth

While Covington eHealth is a new publication, lawyers at Covington & Burling LLP have been writing on topics related to eHealth for many years, including on other Covington blogs. Below is a selection of eHealth-related articles posted to other Covington blogs in the first half of 2014. We encourage you to visit our other sites … Continue Reading

Legal and Practical Challenges Surround Telehealth Implementation

Health care providers and other entities face a host of legal and practical challenges as they implement telehealth and telemedicine initiatives. For example, providers of telehealth services, and the entities creating or hosting telehealth platforms, must determine which federal and state privacy and security laws apply to them.  These laws, such as the federal Health … Continue Reading

Medicare Coverage of Telehealth Services: Current Law and Changes for 2014

Medicare Part B pays for certain health services furnished to rural beneficiaries via an “interactive telecommunications system”—a system that provides for real-time audio and video communication.  Among the covered services are office visits, certain behavioral health services, diabetes self-management training, and medical nutrition therapy.  The practitioner furnishing the service remotely (the “distant site”  provider) may … Continue Reading

Lawmakers and Biotechnology Industry Organization Press OMB to Release E-Labeling Rules

In recent weeks, two sets of stakeholders have urged the Office of Management and Budget (OMB) to release the Food and Drug Administration’s (FDA) proposed rule on e-labeling, “Electronic Distribution of Prescribing Information of Human Prescription Drugs,” 0910-AG18.  On January 22, 2014, the Biotechnology Industry Organization issued a letter urging OMB and FDA to issue … Continue Reading

CMS Delays Meaningful Use Attestation Deadline for Eligible Professionals

On February 7, 2014, CMS announced a one-month delay of the deadline for eligible professionals to attest to their calendar year 2013 meaningful use of Electronic Health Records (EHR) for purposes of compliance with the Medicare EHR Incentive Program.  This moves the deadline from February 28 to March 31, 2014.  In addition, CMS announced it … Continue Reading

CMS Finalizes Rules Allowing Patients to Access Test Results Directly from Laboratories

On February 6, 2014, three agencies within the Department of Health & Human Services (HHS) — the Centers for Medicare & Medicaid Services, the Centers for Disease Control & Prevention, and the Office for Civil Rights — finalized rules to allow patients to directly access test results from laboratories.  See 79 Fed. Reg. 7290 (Feb. 6, … Continue Reading

ONC Releases SAFER Guides to Help Providers Safely Use EHR and Other Technology

On January 15, 2014, Office of the National Coordinator for Health Information Technology (ONC) released the Safety Assurance Factors for EHR Resilience (SAFER) Guides.  The SAFER Guides can be found here. The SAFER Guides, which are part of ONC’s Health Information Technology Patient Safety Action & Surveillance Plan (July 2013), are self-assessment tools designed to help … Continue Reading