Thomas A. Range

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Having spent nearly a decade working for a national biopharmaceutical company, including five years in management, Tom Range possesses invaluable experience in the biotechnology sector, which allows him to better serve his broad client base.  Because he has worked in facilities regulated by the FDA, the State of Florida, and foreign authorities, Tom understands the challenges facing companies whose success depends on their ability to navigate often-murky regulatory waters.

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The Florida Office of Insurance Regulation Amends the Application for Certificate of Authority for Health Maintenance Organizations

Applicants for a health maintenance organization (HMO) certificate of authority (COA) in Florida must use a new application form effective January 28, 2024. After rule development by the Florida Office of Insurance Regulation, the Florida Department of Financial Services adopted amendments to Rule 69O-C1-942, F.A.C. The amendment incorporates changes to the Florida HMO COA application … Continue Reading

ACTION REQUIRED TO AVOID FINES! DEADLINE APPROACHING: Florida Pharmacy Benefit Managers Must Be Licensed as a Third-Party Administrator by January 1, 2024

Pharmacy Benefit Managers (PBMs) take note! Under Florida’s new Prescription Drug Reform Act, PBMs must be licensed as an insurance administrator (also known as a third-party administrator, or TPA). Under this new law, any entity that wishes to provide PBM services after January 1, 2024, must be licensed as a TPA.… Continue Reading

New Florida Law Will Impose A Third-Party Administrator Licensing Requirement for Pharmacy Benefit Managers

On May 3, 2023, the Florida governor signed a comprehensive law (SB 1550) regarding pharmacy benefit managers (PBMs). This new law imposes significant new requirements on PBMs. This article discusses only one of these new requirements: a PBM must obtain a license, called a certificate of authority, to act as an insurance administrator, which is … Continue Reading

Common Errors in State Licensing Applications

As a condition of doing business in the healthcare field, persons and companies must generally obtain the appropriate licenses or approvals. In addition to requirements that apply to all businesses, such as registering corporate entities with the Secretary of State or obtaining local business licenses known as business tax receipts, there are also substantive requirements … Continue Reading

Group Health Plan Sponsors are Getting Serious About Pricing Transparency – Are You Keeping Up?

In early July, the Department of Health and Human Services (HHS), the Department of Labor (Labor), and the Department of the Treasury (Treasury) (collectively, the Departments), along with the Office of Personnel Management (OPM) released an interim final rule related to the No Surprises Act, legislation designed to protect patients from unexpected medical bills. The … Continue Reading

A Glossary of Commonly Used Acronyms in Florida Managed Care

Anyone who interacts with third party payors encounter acronyms on a regular basis. While acronyms are intended to facilitate efficient communication, their use often instead leads to confusion. This blog is intended to provide a brief overview of some commonly used acronyms in managed care. Please note that, although some of the acronyms are specifically … Continue Reading

TV Drug Commercials Must Disclose the Drug’s List Price if HHS Adopts Proposed Rule

We are all familiar with prescription drug television commercials where it sounds like they hired a professional auctioneer to recite the drug side effects so fast you can hardly understand them. The U.S. Department of Health and Human Services (HHS) announced a proposed rule that would require pharmaceutical companies that advertise their prescription drug products … Continue Reading

Florida Federal Court: Escobar Requires Reversal of $348 Million False Claims Act Jury Verdict

The United States District Court for the Middle District of Florida vacated a large jury verdict in a False Claims Act case against the owners and operators of nursing homes because the evidence did not satisfy the materiality standards articulated in the U.S Supreme Court’s 2016 opinion in Universal Health Services v. Escobar. The court’s … Continue Reading

AHCA Sees the Light on Nursing Home Generator Rule, Unplugging Challenge

After Hurricane Irma made landfall in Florida, a nursing home in South Florida lost power, and several residents of that nursing home died allegedly as the result of increased temperatures caused by the loss of air conditioning. In the immediate aftermath of this tragic accident, the Agency for Health Care Administration (AHCA) (for nursing homes) … Continue Reading

Insurers Challenge Retroactive Application of New Florida Law that Requires Comparison of Names of Accounts to Death Master File

Amendments to the Florida Disposition of Unclaimed Property Act in 2016 made significant changes to unclaimed property presumptions and insurance company obligations. See § 717.107, Fla. Stat. (2016) (the Act). Among other things, the Act: (a) revises conditions of when certain insurance policies or annuity contracts are deemed matured and the proceeds are due and … Continue Reading

Medical Devices And Risks Of Unauthorized Disclosure Of Protected Health Information

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) kicked off the holiday season by publishing a settlement agreement under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) relating to the theft of an unencrypted laptop from a hospital. Lahey Hospital and Medical Center (Lahey), a nonprofit teaching hospital … Continue Reading

Can We Talk? Florida Court Rejects Latest Challenge to Med Mal Presuit Authorization Law

In the latest challenge to a Florida law designed to promote early settlement of meritorious medical malpractice claims, the Florida First District Court of Appeal recently rejected a plaintiff’s arguments that 2013 amendments to the law violated the Florida Constitution. See Weaver v. Myers, Case No. 1D14-3178 (Fla. 1st DCA July 21, 2015). The court also … Continue Reading

Recent HHS Settlement Highlights Risks of Electronically-Sharing Protected Health Information

On July 10, 2015, the United States Department of Health and Human Services Office for Civil Rights (OCR) announced its second settlement of the year for violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). St. Elizabeth’s Medical Center (SEMC), a tertiary care hospital in Massachusetts, must pay $218,400 and adopt a “robust corrective … Continue Reading

HHS Settlement: Dumpster-Diving Leads to Settlement for Improper Disposal of Documents Containing Protected Health Information

The U.S. Department of Health and Human Services Office for Civil Rights (HHS) recently announced that it has reached an agreement with a small pharmacy to resolve potential HIPAA violations. The settlement arose from the disposal of unsecured paper documents containing protected health information (PHI) of the Pharmacy’s customers. The more well-known data breaches usually … Continue Reading

Talk Amongst Yourselves: HIPAA Does Not Preempt Florida Med Mal Presuit Authorization Law

A federal appellate court recently concluded that the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) does not preempt a Florida law that requires aggrieved patients to authorize the release of their protected health information as a presuit condition to suing a medical provider for negligence. See Murphy v. Dulay (11th Cir. Oct. 10, … Continue Reading

HHS Settlement: Reminder That HIPAA Applies to Local Governments Big and Small

The U.S. Department of Health and Human Services Office for Civil Rights (HHS) recently announced that it had reached an agreement with Skagit County, Washington to settle potential HIPAA violations involving the County Public Health Department. The settlement arose from a 2011 incident involving the unauthorized disclosure of electronic protected health information (ePHI) of over … Continue Reading

HHS Gives a Thumbs Down for Stolen Thumb Drive

On December 26, 2013, the U.S. Department of Health and Human Services Office for Civil Rights (HHS) announced that it had reached an agreement with a Northeastern dermatology practice to settle potential HIPAA violations arising from a 2011 theft of an unencrypted thumb drive containing patient information. This is HHS’ first settlement with a covered … Continue Reading

Leased Office Equipment Results in $1.2 million HHS Settlement to Resolve Possible HIPAA Violations

Leasing office equipment can provide businesses with many benefits, such as flexibility, favorable tax treatment, and access to the latest technology. However, leasing can also present an unexpected source of liability for entities covered by the HIPAA Privacy and Security Rules. A recent $1.2 million settlement between the U.S. Department of Health and Human Services … Continue Reading
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