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As the COVID-19 vaccine is distributed across the country, employers must consider which policies and requirements they will follow in determining whether employees are required to be vaccinated before returning to the workplace.

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Employers should review the new guidance pertaining to travel and voluntary training and should realign policies and pay practices where necessary to ensure compliance.

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On March 30, 2020, the Secretary of Health and Human Services (HHS) issued nationwide blanket waivers of Section 1877 of the Social Security Act (42 U.S.C. § 1395nn), otherwise known as the physician self-referral law or Stark Law, for certain “COVID-19 Purposes,” as further defined in the waivers and discussed in this Alert.

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