Welcome to your daily briefing on healthcare developments in Colorado. Today we're covering 4 key stories including updates on colorado healthcare headlines, background & context. Let's dive in.
1 story
CDPHE has published a geospatial dataset of regulated health facilities across Colorado as point-location addresses.
Healthcare professionals in CO can use this resource to identify facility locations, analyze geographic service gaps, and support emergency preparedness and network planning.
Reach healthcare professionals
3 stories
A vendor is a business associate if they create, receive, maintain, or transmit PHI on behalf of the covered entity. They are NOT a business associate just because they happen to be in a building with PHI or could conceivably access it. The functional test matters, not the proximity test.
Forcing BAA execution on vendors who do not meet the functional test creates contractual bloat and weakens the negotiating position with vendors who actually do. Failing to execute BAAs with true business associates exposes the covered entity to OCR enforcement.
Covered entities must annually recertify their 340B eligibility through HRSA. Missing the recertification window pushes the entity to inactive status, which means immediate loss of 340B pricing and potentially diversion violations on previously dispensed drugs. Reinstatement requires a new application.
The discount value of 340B pricing for a covered entity often exceeds six figures annually. Letting the recertification lapse for paperwork reasons is one of the most expensive administrative errors in the regulation.
Three application defects routinely delay payor enrollment: incomplete work-history explanations for any gap over 30 days, a malpractice carrier-history that does not reconcile with the explanation, and CAQH attestation that has lapsed. Each forces a back-and-forth with the credentialing committee.
A new clinician without active payor enrollment cannot bill for covered services for most plans. Each month of delay is foregone revenue that does not retroactively recover.
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