Stephen Rose has more than 25 years of experience representing clients in the healthcare industry. His practice focuses on Medicare / Medicaid reimbursement, defending healthcare providers during and after government audits, developing and implementing corporate compliance plans, addressing certificate of need issues, and assisting hospitals with credentialing and privileging issues.
He has also worked for the Washington State Medical Association preparing and presenting educational materials for their membership on both the HIPAA Privacy Rule and Security Standards. Mr. Rose is a frequent lecturer on HIPAA and government audit issues.
Stephen has represented healthcare providers responding to HIPAA complaints and breaches. With respect to HIPAA complaints, Stephen has represented dozens of providers responding to initial inquiries issued by investigators for the Office of Civil Rights. He has also assisted providers addressing situations where they needed to determine whether the disclosure of certain information constituted a “breach” under the HIPAA/HITECH regulations. He has dealt with breaches as small as one record and as large as involving over 10,000 records. Additionally, he routinely assist providers with updating and maintaining their HIPAA policies and procedures.
Community Activities
- Member, Board of Trustees, Greater Northwest Chapter, National Multiple Sclerosis Society, 2005-2008
- Vice President, Western States Healthcare Compliance Association, 1999-2005
- Member, Board of Directors, American Diabetes Association of Washington State, 1984-1988
Publications
- "HIPAA Audits Begin in 2012," Garvey Schubert Barer Legal Update, January 3, 2012.
- "HHS Awards Contract to Conduct HIPAA Audits," Garvey Schubert Barer Legal Update, November 2011.
- "Certificate of Need Laws - The Beginning of the End?," Garvey Schubert Barer Legal Update, September 14, 2011.
- "ACOs: Will There be Savings to be Shared?," Washington Healthcare News, June 8, 2011.
- "Public Hospital Districts and Non-Healthcare Related Tort Claims for Damages: Is Your District Meeting All of the Requirements?," Garvey Schubert Barer Legal Update, April 28, 2011.
- "New Proposed Federal Regulations for Accountable Care Organizations," Garvey Schubert Barer Legal Update, April 21, 2011.
- "The Washington Supreme Court Allows Private Lawsuits Against Health Care Providers Who Do Not Report Suspected Child Abuse," Garvey Schubert Barer Legal Update, February 2011.
- "Update: Health Care Reform," Garvey Schubert Barer Legal Update, February 4, 2010.
- "Individual Mandate Requirement of Healthcare Reform Ruled Unconstitutional," Garvey Schubert Barer Legal Update, December 30, 2010.
- "Medicaid Program Recovery Audit Contractors," Garvey Schubert Barer Legal Update, December 1, 2010.
- "The Washington Public Records Act - New Developments," Garvey Schubert Barer Legal Update, October 2010.
- "A Healthcare Primer for Providers," Puget Sound Business Journal, October 1, 2010.
- "HIPAA: Proposed Regulations to the HIPAA Privacy, Security and Enforcement Rules Under HITECH," Garvey Schubert Barer Legal Update, July 30, 2010
- "Hospital Medicare Reimbursement: Moving to Reimbursement Based on Quality of Care," Washington Healthcare News, Volume 5, Issue 7, July 2010.
- "New Developments Regarding Ancillary Services," Garvey Schubert Barer Legal Update, May 5, 2010.
- "OIG: Recovery Audit Contractors' Fraud Referrals," Article provided by the Department of Health and Human Services, Office of Inspector General. Written by Daniel R. Levinson, Inspector General.
- "HIPAA Reference Charts for Healthcare Providers," Garvey Schubert Barer, January 28, 2010.
- "RAC Audit Appeals: Delaying Recoupment of Medicare Funds Pending RAC Appeal," Garvey Schubert Barer Legal Update, August 13, 2009.
- "New Certificate of Need Regulations Proposed in Alaska," Garvey Schubert Barer Legal Update, August 4, 2009.
- "Increased Risk of False Claim Act Investigations and Litigation," Garvey Schubert Barer Legal Update, July 30, 2009.
- "Alaska Medicaid Audits," Garvey Schubert Barer Legal Update, June 22, 2009.
- "Summary of the Red Flags Rule," Garvey Schubert Barer Legal Update, April 22, 2009.
- "Maintaining an Effective and Low Cost Compliance Program for Rural Hospitals," Washington Healthcare News, Volume 4, Issue 3, March 2009.
- "RAC Audits Back on Track," Garvey Schubert Barer Legal Update, February 20, 2009.
- "HIPAA Gets 'Stimulated'," Garvey Schubert Barer Legal Update, February 5, 2009.
- "RAC Audit Recoveries: One Billion Dollars and Counting," Garvey Schubert Barer Legal Update, September 18, 2008.
- "Long-Term Care Facilities," Washington State Hospital Association, Washington Health Law Manual, 3rd Ed., Chapter 11, August 2008.
- "Medicare Stops Paying to Treat Medical Mistakes," Puget Sound Business Journal, January 11, 2008.
- "Alaska Medicaid Audits," Alaska Pharmacy Association, The Alaska Pharmacist, Spring Quarter, 2007.
- "Avoiding HIPAA Headaches," Washington State Bar Association, Real Property, Probate and Trust, Volume 31, No. 5, Spring 2004.





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