This document is intended to serve as a checklist for AMC legal offices, as they triage the unprecedented demands that they and their organizations more broadly face as a result of the COVID-19 crisis.
The table that follows summarizes key issues and considerations for AMCs arising from statutory, regulatory, and industry responses to COVID-19. To serve as a useful checklist, the table is high-level. However, where applicable, for those seeking a deeper dive, we provide links in the footnotes to more detailed assessments.
The table addresses the following topics:
- Medical Education (Section A)
- Liquidity and Municipal Bond Defaults (Section B)
- Sources of Relief Funding (Section C)
- Reimbursement (Section D)
- Care Delivery Models and Clinical Care (Section E)
- Staffing Shortages (Section F)
- Labor and Employment (Section G)
- Clinical Research (Section H)
- FDA Regulatory (Section I)
- Liability (Section J)
- Tax (Section K)
- Patient Privacy and Confidentiality (Section L)
- Collaborations (Section M)
Regulatory developments are coming quickly, and this checklist unavoidably will soon become out of date. This last was updated on May 5, 2020.
Footnotes
1 COVID-19 Issues for AMCs, ROPES & GRAY (Apr. 7, 2020).
2 Id.
3 Id.
4 Teleconference, COVID-19: Liquidity and Municipal Bond Considerations for Hospitals, ROPES & GRAY (March 31, 2020) (teleconference slides and recording available upon request).
5 HHS Provides Guidance on Additional Distributions from the Public Health and Social Services Emergency Fund, ROPES & GRAY (Apr. 23, 2020); Public Health & Social Services Emergency Fund Implementation Guidelines as of April 15, 2020 , ROPES & GRAY (Apr. 16, 2020); HHS Initiates Initial $30 Billion Distribution of the $100 Billion Public Health and Social Services Emergency Fund, ROPES & GRAY (Apr. 10, 2020); COVID-19 Issues for AMCs , ROPES & GRAY (Apr. 7, 2020); CARES Act – Financial Relief Sections Applicable to Health Care Providers , ROPES & GRAY (Apr. 1, 2020).
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Originally published 7 May, 2020
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.