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Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Thought Leadership

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Healthcare Private Equity Compliance Checklist

The complex and ever-changing healthcare regulatory and enforcement environment, including increased focus on the role of private equity firms in their portfolio companies, make compliance a top priority for private equity firms investing in healthcare companies. The best way to limit your exposure as a private equity firm is to avoid a compliance misstep in the first place. Additionally, an effective and robust compliance program for your portfolio healthcare company makes it much more attractive to potential buyers and helps you avoid an unexpected and costly investigation or valuation hit down the road. Download the Healthcare Private Equity Compliance Checklist to assess whether your portfolio company's compliance program is up-to-date.

Click here to download the checklist.

Top 10 Questions Banking Leaders Should Be Asking About Cybersecurity

Publications

July 20, 2015

In remarks to the American Bankers Association Summer Leadership Meeting on July 14, 2015, Deputy Secretary of the Treasury Sarah Bloom Raskin addressed issues especially timely and important to financial institutions -- cybersecurity and cyber-resiliency. Recognizing the unique threat cyber-attacks pose to the banking system, the Treasury Department has made ensuring cybersecurity a high priority. Deputy Secretary Raskin noted that the litany of cyber-risks could be "uniquely devastating" to the financial sector, which is heavily invested in e-commerce and e-banking.

Based on the assessment of the unique risks to the financial sector, Deputy Secretary Raskin posed 10 questions designed to better equip the banking leaders in their efforts to oversee cybersecurity efforts at their respective institutions:

    1. Does our bank embed cybersecurity into our governance, control and risk management systems?

    2. Have we remained vigilant about systematically identifying our key assets, those that provide high-value targets for malicious cyber actors?

    3. Have we tailored our security controls to the specific cyber risks presented by each key network, system or set of sensitive data?

    4. How do we prioritize the implementation of enhanced controls around key networks, systems and sensitive data?

    5. Have we reviewed the FFIEC Cybersecurity Assessment Tool and appropriately incorporated it into our approach to cyber-risk management?

    6. Have we designated specific professionals to handle our cybersecurity strategy and provided them with the authority, resources and access they need to effectively perform their work?

    7. Have we trained our personnel on our cybersecurity policies?

    8. How do we ensure that our insurance coverage matches our cyber-related risks?

    9. Does our cyber-risk insurance impose "minimum required practices," which may lead to denial of coverage if not followed?

    10. Do we practice basic cyber hygiene?
      1. Do we require multi-factor authentication before allowing access to our networks, systems and data?
      2. Have we restricted special, high-level access to only those who need it?
      3. Are we doing regular maintenance and consistently patching our software?
      4. Are we effectively scanning our systems for malicious activity?

Deputy Secretary Raskin's entire remarks can be found here.

For more information on other financial institution cybersecurity and privacy matters, please contact the author, Anthony McFarland.


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