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“The Sunshine Act” is about to take effect beginning on September 30, 2014. This is a national program being implemented by the Center for Medicare & Medicaid Services (CMS) in order to be more transparent and responsible to the general public. CMS is mandated to publish reported data on September 30, 2014. The first Open Payments program cycle is a partial data collection period of five months (August 1 through December 31, 2013). Each Open Payments program cycle beyond 2013 will consist of a full 12 months of calendar-year data to be collected and reported to CMS.

The program allows physicians and teaching hospitals to register and review the financial data submitted by applicable manufacturers and group purchasing organizations to initiate disputes if necessary before the data is made public.   

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In June, 2014, the Board of Governors of the Federal Reserve System, The Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency issued FIL 30-2014, “Intercompany Tax Allocation Agreements.”  The regulation provides guidance on tax allocation policies in the instances where a Holding Company Structure exists.  As a reminder, compliance is required no later than October 31, 2014.  For further information or assistance, please contact Brenda DeCosta or David St. Yves of Marcum’s Financial Institutions Services Group. 

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It is becoming increasingly difficult to make financial statements when carriers are making modifications to the networks on an ongoing basis. This article highlights some of what is occurring nationwide. It becomes increasingly important to be able to do financial modeling rapidly and accurately on a "what if" basis. Many of the physicians who receive notifications from UnitedHealth will need to be changing their employee and physician makes if they have significant portions of their patient revenue from this carrier. We have already found some physician and physician group clients who have had to make short-term (less than six months) changes in their physician and physician extender employees based on gains and losses from the Affordable Care Act and related network changes.

Published Date: June 17, 2014
By: Rachael Zimlich  

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Cybersecurity:  Investing in your Firm’s Future

Recent cybersecurity breaches such as Target and Neiman Marcus have caused the U.S. government to start implementing security initiatives throughout all sectors to help defend against cyber-attacks. According to a 2012 global survey of securities exchanges, 89% identified cyber-crime as a potential systemic risk and 53% reported experiencing a cyber-attack in the previous year.* 

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The creation of the Financial Reporting and Audit Task Force (“Task Force”) was announced by the Securities and Exchange Commission (“SEC”) on July 2, 2013 in an effort to strengthen the agency’s efforts to identify and prosecute securities law violations as they relate to fraudulent or improper financial reporting and audit failures. 

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In the August 22, 2014 Federal Register, the Centers for Medicare and Medicaid Services (CMS) issued CMS-1607-F. This Final Rule revises the Medicare hospital inpatient prospective payment systems (IPPS) for payments to acute care hospitals for discharges occurring on or after October 1, 2014. The Final rule also included certain important changes from the Proposed Rule relating to the Connecticut rural wage index.  

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In accordance with the Patient Protection and Affordable Care Act of 2010 section 3132 requires CMS to collect appropriate data and information to facilitate hospice payment reform. On August 20, 2014, CMS released their final ruling, wage index and payment updates entitled CMS-1609-F 42 CFR Parts 405 and 418. 

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With more than 2,000 entrepreneurs, investors, data scientists, researchers, policy experts, government employees and more in attendance, the Department of Health and Human Services (HHS) is releasing new data and launching new initiatives at the annual Health Datapalooza conference in Washington, D.C. 

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Effective July 18, 2014, the Division of Banks issued “Final Amendments to 209 CMR 43.00: Audit Requirements for Credit Unions”. The purpose of the amendment is to clarify the responsibilities of credit union audit committees, as well as to establish audit frequency and share verifications requirements. The amended regulation are as follows: 

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A technical termination of a partnership occurs when there is a sale or exchange of 50% or more of the total interest in the profits and capital of a partnership within a 12-month period.  

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