On August 29, 2024, the Office for Civil Rights of the United States Department of Health and Human Services (“HHS-OCR”) withdrew its appeal of an order by the United States District Court for the Northern District of Texas’ (“District Court”) declaring unlawful and vacating a portion of an HHS-OCR Bulletin
Jonian Rafti
Jonian Rafti is an associate in the Corporate Department and a member of the Health Care Group. He regularly represents private equity investors, health systems, management companies, physician groups, and lenders in complex transactional and health care regulatory matters.
Since the start of his career, Jonian's practice has exclusively focused on representing a variety of clients in the health care sector. He leverages this industry experience to provide practical and market-driven insight to clients undertaking mergers, acquisitions, joint ventures, financings and other business transactions. In addition to his transactional practice, Jonian provides counsel on a range of regulatory requirements governing the practice of medicine and the health care industry, including the Federal Anti-Kickback Statute, Civil Monetary Penalties Law, Health Care Fraud Statute, Physician Self-Referral Law (Stark Law) and their state counterparts. He also advises clients on corporate practice of medicine restrictions, HIPAA and health data privacy, and health care technology matters.
Jonian is a Certified Information Privacy Professional (CIPP/US) and a Certified Artificial Intelligence Governance Professional (AIGP). As a law student, he worked at the Charities Bureau of the NY Attorney General’s Office on governance and regulatory disputes affecting state not-for-profit corporations.
He has previously served as member of the Board of Directors and Vice-Chair of The Andrew Goodman Foundation, and member of the Bard College Center for Civic Engagement's Young Alumni Advisory Council.
OIG Issues Final Information Blocking Enforcement Rule and Highlights the Potential for Referrals to the FTC and FCA Liability
On June 27, 2023, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) released its final rule (“Final Rule”) implementing penalties for information blocking.
The Final Rule codifies the prohibition on “information blocking” introduced by the 21st Century Cures Act (“Act”), which was…