Hospital Price Transparency Rule: Full Steam Ahead
Verrill, November 2020

Neither COVID-19 nor continued legal challenges appear likely to derail the Centers for Medicare & Medicaid Services (CMS) Hospital Price Transparency Rule from going into effect on January 1, 2021. Hospitals therefore should continue to comply with the requirements by the deadline. This is not to be confused with two other recently finalized rules requiring hospitals to report their average negotiated prices with Medicare Advantage plans and insurers to provide enrollees with personalized cost-sharing estimates. 1...

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What Employers Need to Know About The Families First Coronavirus Response Act - An Animation
Verrill, October 2020

Navigating the ins and outs of the Families First Coronavirus Response Act (FFCRA) can be difficult for employers. This animation seeks to illustrate some of the most important takeaways. Transcript (see animation below): Hi, I'm Tawny, a partner in Verrill's Labor & Employment Practice Group. The Families First Coronavirus Response Act provides relief for many employees who may have a need to be out of work to care for children whose school or care provider is closed as a result of COVID-19...

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News Flash: HHS Issues Statement Removing Premarket Review Requirements for Laboratory Developed Tests (“LDTs”), Including COVID-19 LDTs
Verrill, August 2020

What happened? On August 19, 2020, the U.S. Department of Health and Human Services (“HHS”) issued a single paragraph statement rescinding U.S. Food and Drug Administration (“FDA”) guidance documents concerning premarket review of Laboratory Developed Tests (“LDTs”) and eliminating the requirement for premarket review of LDTs, in the absence of notice-and-comment rulemaking. Submission by labs of a premarket approval application, premarket notification, or Emergency Use Authorization (“EUA”) request may be done on a voluntary basis – and FDA will adjudicate voluntary submissions...

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PPP Forgiveness Planning Scenarios
Verrill, August 2020

How to use this article: You already know that the Paycheck Protection Program (PPP) is highly complex, with intertwining conditions, exceptions, and definitions that defy simple explanation. This article assumes that you are pretty familiar with PPP terminology as relates to your business. We present nine different scenarios commonly found within the PPP recipient pool and offer an intentionally over-simplified discussion of when and how you should apply for forgiveness. Our goal here is to provide a useful starting point for you to plan the forgiveness application for your particular company and situation...

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EU-U.S. Privacy Shield Invalidated: Does Your Company Have a Plan B?
Verrill, July 2020

On Thursday, July 16, 2020, the Court of Justice of the European Union (“CJEU”) invalidated the EU-U.S. Privacy Shield (“Privacy Shield”) in Data Protection Commissioner v. Facebook Ireland and Maximillian Schrems (Case C-311/18) The CJEU’s ruling voiced concern that the Privacy Shield does not adequately protect EU data subjects’ personal data from U.S...

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