Practical, informed health care regulatory advice 

Sarah Coyne’s practice is truly "soup to nuts" for health care providers (and their partners) on so many issues that it would be impossible to list them all here. But some of the highlights include: 

• Regulatory hospital law with business insight, including False Claims, Stark Law, Anti-Kickback Statute, EMTALA and state laws
• Federal conditions of participation and conditions of payment, including provider-based billing
• Medical staff structure, governance and documentation to achieve compliance with regulatory and accreditation requirements.
• Reporting obligations of health care entities.
• Rural and critical access hospitals, rural health clinics and federally qualified health centers

Sarah's goal is to identify practical clear solutions through the quagmire of health care regulation for hospitals and other clients. She stays on the cutting edge of all legal developments affecting the hospital industry and updates her clients regularly and (usually) hilariously.

Bar Admissions

• Wisconsin

Education

• University of Wisconsin - Madison (O.T.R., with honors, 1987)

• University of Wisconsin - Madison (B.S., 1987)
  • With honors

• University of Wisconsin Law School (J.D., cum laude, 1995)
  • Order of the Coif

• "A Practical Roadmap For Navigating Medical Staff Legal Nightmares In Current Times"
• "A Tough Act to Follow: Wisconsin's Quality Improvement Act Great for Health Care Providers"
• "ACA's Future Hangs in the Balance"
• "Advanced Practice Clinician Hospitalists: An Overview of the Complex Legal Landscape"
• "APNP and CNM Hospitalist Programs: What Would It Look Like, Can We Do It, and Is It Worth the Risk?"
• "Breach Notification and Disclosures to Law Enforcement"
• "De-identified Data"
• "Disclosures to Law Enforcement: Confidentiality Considerations"
• "Don't Just Kick Back! Pay Attention To Health Care Compliance Laws (Even If You Are Not A Provider)"
• "Employment and Telemedicine Arrangements Between Hospitals and Practitioners: Compliance, Contractual, Reimbursement and Medical Staff Considerations"
• "EMTALA and Patients Leaving AMA: How to Keep your Cool When Things Get Heated"
• "From Chaos to Calm: Managing A Medical Practice in a Complex Environment"
• "Fun with HIPAA: A Refresher and Client Update"
• "Fun With Medicaid Managed Care"
• "Health Law"
• "Health Law"
• "Health Law"
• "Health Law"
• "HIPAA Privacy 101"
• "HIPAA Review: Keeping PHI Private and Secure"
• "Hospital Board Compliance: Education Update"
• "How The FCA Is Weeding Out Medicare And Medicaid Fraud"
• "It’s Your Business...to know about Health Care Reform"
• "Legal and Ethical Issues in Reproductive Care"
• "Legal Boundaries for Physicians Helping Pregnant Women"
• "Let's Get This Party Started: Practical Issues for Implementing an APC Hospitalist Program"
• "Medical Staff Corrective Action: Dabble at Your Own Risk!"
• "Mental Health and Substance Abuse Records: Putting Together the Puzzle"
• "Navigating the Stormy Waters: Strategies for Medical Staff Professionals to Ensure Smoother Sailing"
• "Overcoming Day-to-Day Legal & Practical Hurdles"
• "Physician Employment and Medical Staff Matters - Fun Times For HR Directors!"
• "Real World ROI: To Release or Not to Release?"
• "Reinventing Customer Service in Healthcare: Lessons Learned from the Best"
• "Responsibilities and Liabilities of Non-Profit Directors"
• "Stay Out of Jail and Be Compliant - the new Final HIPAA Rule on Enforcement and Notices of Privacy Practices"
• "Strategies for Complying with Evolving HIPAA and HITECH Regulations"
• "Telehealth Flexibilities: Reimbursement, Licensing and Credentialing"
• "The 411 On Using Text Messages To Issue Physician Orders"
• "The False Claims Act: Not Just for Health Care Anymore"
• "The Past, Present and Future Of Texting Clinical Information"
• "The Practitioner’s Duty To Inform (And Practical Documentation Tips)"
• "The Proverbial Rock and Hard Place"
• "The Rules and the Realities: Minor Patients and Patients Deemed Incompetent or Incapacitated"
• "The Stark Law 2019: Good Things on the Horizon for Providers"
• "The Stark Law: A proactive approach to audit and compliance"
• "The Stark Law: A Proactive Practical Approach to Internal Audit"
• "TXT U L8R: Should Your Physician Be Texting Orders?"
• "Understanding Health Care Provider Credentialing and Scope of Practice"
• "Understanding the False Claims Act: Know when it applies and when to be thankful it doesn't"
• "Using Deferred Compensation to Incent On-Call Coverage"
• "What is in the Final HIPAA Rule, What is Not, and What To Do About Business Associates"
• "What Non-Health Care Lawyers Need to Know about HIPAA"
• "Who’s Been Snooping in My Records?"
• "WisHHRA - A Scintillating Annual Update"
• A Few Clarifications About the CMS Mandatory COVID-19 Vaccination Rule
• A HIPAA Breach Notification Handbook: Everything You Ever Wanted to Know About Breach Notification Requirements but Were Afraid to Ask
• A Practical HIPAA Compliance "To Do" List: Covered Entities And Business Associates Have New Affirmative HIPAA Obligations Under President Obama's Stimulus Package!
• All I Want for Christmas Are Two New Wisconsin Guardianship Rules!
• Annie Get Your Gun…Unless You See a Sign - Health Care Implications of Wisconsin's New Concealed Carry Law
• Answers to Questions About USP's Notice of Intent to Revise New Compounding Standards
• Because Health Care is Not Regulated Enough: Very Specific Compliance Training Program Required as of January 1, 2016!
• Because You Needed Another Regulatory Headache Right Now: Electronic Notifications of Admission, Transfer and Discharge Required in 2021
• Bill Would Exempt Many Businesses, Health Care Providers from the FTC's Red Flags Rule
• Budget Bill Makes Changes Affecting Patient Health Care Records and Treatment Records
• Change of Deadline: Three More Months To Comply With FACTA Red Flags Rule
• Chocolate, Beaches, Sunsets, Wine, and the Stark Law: One of These Things is Not Like the Others!
• Ciox Case Changes the HIPAA Rules on Patient Rate Caps for Access to Health Records
• Ciox Case Changes the HIPAA Rules on Patient Rate Caps for Access to Health Records… Which Can Be Very Confusing in Wisconsin!
• Civil Rights Compliance for Hospitals in Wisconsin
• CMS Delays TJC Deadline To Comply With Existing Telemedicine Rules
• CMS Issues Long-awaited Final Rule Regarding the Identification and Return of Medicare Overpayments
• CMS Proposes Changes to the Physician Supervision Requirement for Outpatient Hospital Services
• CMS Publishes Stark Law Self-Disclosure Protocol
• CMS Says: No Need to Revise EMTALA to Apply to Inpatients
• CMS Vaccine Mandate Halted (For Now) in Certain States
• CMS Vaccine Mandate – Ban Lifted In 26 States
• CMS Vaccine Mandate: Compliance Dates Clarified
• CMS Will Not Enforce Vaccine Mandate for Now
• Confidentiality of Substance Abuse Records: Everything You Want Someone Else to Know so You Don't Have to Remember It.
• COVID-19 and the National State of Emergency: The Impact on Hospitals
• Current Cases: Medical Staff Nightmares And Fairy Tales
• Déjá Vu All Over Again? The FTC Delays the Red Flags Rule to November 1
• DHHS Waives Certain Regulatory Requirements for Hospitals and Practitioners in Light of COVID-19
• Exciting Holiday Reading: How to De-Identify Health Information!
• FDA Clarifies Investigational Drug Issues
• Federal Trade Commission Issues Proposed Breach Notification Rule
• Happy 2012! Here's to a Whole New "Stark" to the New Year
• Have the "HIPAA Police" Finally Arrived? HHS Launches Formal Audit Program
• Heads Up! Affirmative Compliance Action Needed by January 23, 2018!
• Health Care Providers Beware: Congress Expands The False Claims Act
• Health Care Workforce COVID-19 Vaccination Mandate: Start Your Engines!
• Health Information
• Health Law Chapter of the 2009 Annual Survey of Wisconsin Law
• Helpful Guidance from OCR on Conducting a Security Risk Analysis
• HHS Pulled a Fast One - Proposed Expansion of HIPAA's Accounting Requirements
• HIPAA Breach Notification Goes Live: Providers May Now Report Breaches to DHHS Via Online Form
• HIPAA Final Rule On Breach Notification: Shark Or Minnow? (Discuss Amongst Yourselves)
• HIPAA Has Some New Teeth: Update on Interim Final Rule On "Improved Enforcement" Under HITECH
• HIPAA Rule Update: Call Us (To Help Revise Your Notice of Privacy Practices), Maybe
• HIPAA Rule Update: Extended Compliance Time for "Grandfathered" Agreements
• HIPAA Rule Update: Stop, Drop . . . and Comply - Understanding the New Restrictions on the Sale of PHI and the HIPAA Enforcement Rule
• Hospitals Advised to Postpone Elective Procedures During COVID-19 Crisis
• Hospitals May Assist With Premium Payments for Patients Who Purchase Insurance Through a State or Federal Exchange / Marketplace Without Fear of Anti-Kickback Liability
• Hospitals: Are Your Visitation Policies in Shape?
• Hospitals: Watch Out for Tax Implications of Physician Loan Agreements - Forgiven Repayments Might Be Taxable Wages!
• How To Avoid The HIPAA (HITECH) Security Breach Notification Requirement: DHHS Issues (Timely!) Guidance On Methodologies To "Secure" Protected Health Information
• I am a Doctor and I Play One on TV: Wisconsin's Telemedicine Rules Are Now in Effect!
• Industry Hot Topics: OCR Guidance on Telehealth Privacy and Security and De-identification
• It's Déjá Vu All Over Again . . . Again: FTC Delays Red Flags Rule until June 1, 2010; Congress May Exempt Small Employers
• It's Finally Here! HHS Releases the Final Rule to Modify the HIPAA Privacy, Security, Breach Notification and Enforcement Rules
• Joint Commission Issues Sentinel Event Alert on Cybersecurity in Health Care
• Key Considerations for Healthcare Providers Responding to Law Enforcement Requests
• Looming Deadlines - Fun Fun Fun!
• Medical Staff Structure And Bylaws: Current Trends And Best Practices
• More HIPAA, Anyone?
• New Guidance and New Deadlines for CMS Vaccine Mandate
• No Whammies! New CMS Reimbursement & Resident Reductions Take a Hit on Teaching Hospitals' Bottom Lines
• Not So Fast - Government Cautions Against Third-Party Payment of Premiums for Qualified Health Plans
• OIG Stocking Stuffers: Five New Anti-Kickback Statute Safe Harbors Added
• Oops, They Did it Again: The FTC Extends the Red Flags Rule Deadline Until December 31, 2010
• Out with the Old, In with the...Older? DHS Returns to a 24-Hour Timeframe for Authentication of Verbal Orders
• Physician Assistants May Sign Their Own Prescriptions Without Physician Countersignature (With Some Caveats, Of Course!)
• Proposed IRS Regulations: Burying Tax-Exempt Hospitals Under More Red Tape
• Say What? Concealed Knives and Switchblades Are Now Permissible Without a License
• Speak Now or Forever Hold Your Peace on Third-Party Payment of Marketplace Insurance Premiums
• Staying Vigilant, Covered Entities! The Interim Breach Notification Rule is Still in Effect!
• Substance Abuse Disorder Records (42 CFR Part 2) Final Rule Is Here!
• Substance Abuse Disorder Records (42 CFR Part 2) Proposed Rulemaking Works Toward HIPAA Alignment
• Supreme Court Unblocks CMS Vaccine Mandate - Implement Those Policies!
• Telehealth Payment Expands for Wisconsin Medicaid Patients
• The "Individual Mandate" Upheld Under Congress' Power to Tax; Parts of Medicaid Expansion Upheld
• The OIG Narrows the Self-Disclosure Protocol to Exclude Stark Violations
• The Telemedicine Yo-Yo: CMS Proposal Would Allow Hospitals to Privilege Telemedicine Providers by Proxy
• Time Running Out on Identity Theft Rules Deadline
• Two Months Since Issuance of the Meaningful Use Rules: Questions Remain Despite CMS Guidance
• TXT U L8R: Should Your Physician Be Texting Orders?
• UPDATE: CMS Vaccine Mandate Now Temporarily Halted Nationwide
• Watch OUT! HIPAA: $2.4 Million Settlement
• We're Not in Fairyland Anymore - Recent Ruling Gives Life to the DOL's Home Care Rule
• What Does Wisconsin Medical Examining Board’s New Chaperone Rule Mean for Hospitals?  Not Much.
• WIRED for Health Act
• Wisconsin Legislature Amends Emergency Detention Statute
• Wisconsin State Bar Annual Survey of Wisconsin Law, Health Law Chapter
• Wisconsin State Bar Annual Survey of Wisconsin Law, Health Law Chapter
• ​Compliance Oversight for Health Care Boards of Directors
• ​Fun with Medicaid Managed Care: Network Adequacy Standards and More!
• ​Healthcare in the Crosshairs: OSHA's Continued Focus on Inpatient Healthcare Providers
• ​Ticking Crocodiles Are Not Necessarily Trying to Eat You: Why the First Case to Interpret the ACA 60-day Repayment Rule May Not Be as Scary as You Think
• “3rd Annual Ethics Symposium: Ethical Issues of Medical Documentation"
• “A Practical Approach to Complying with EMTALA”
• “Fundamental Obligations of Health Care Organization Boards: What Every Board Member Needs to Know!”
• “HIPAA for Litigators, for the Wisconsin Defense Counsel"
• “Practical Management of Medical Staff Corrective Action”

Seminar

• 2022 Fall Virtual HIPAA COW Conference
• Practical Answers to Thorny Questions
• Practical Management of Medical Staff Corrective Action
• Protecting Your Organization From Caregiver Misconduct (And Its Many Legal Repercussions)
• Substance Abuse Disorder Records (42 CFR Part 2) Final Rule Is Here!
• Telehealth Flexibilities: Reimbursement, Licensing and Credentialing