United States: Weekly Washington Healthcare Update: April 14, 2014

Last Updated: April 17 2014
Article by Stephanie A. Kennan and Brian J. Looser

This Week: HHS Secretary Sebelius resignation... CMS releases data on Medicare physician payments... HHS-OIG finds Medicare home health claims often lack necessary documentation.



House-Passed Budget Includes Major Revisions to Medicare, Medicaid

On April 10, the House passed a budget proposal for FY 2015 by a vote of 219-205. The proposal would reduce the nation's deficit by $5.1 trillion over 10 years. It would create a voluntary private plan option for Medicare that would begin in 2024 and allow seniors a choice of private plans with traditional coverage or the traditional fee-for-service Medicare program. Another major health-related provision is that the proposal would shift Medicaid's current federal matching payments to states into a block grant program. Opponents say this would shift too much uncertainty on the states. The proposed budget would also repeal the ACA and require means-testing for Medicare premiums paid by higher-income beneficiaries. No Democrats voted for the measure, and it is unlikely to advance in the Senate.

Energy and Commerce Hearing Examines FDA, DEA Drug Oversight

On April 7, 2014, the House Energy and Commerce Subcommittee on Health held a hearing entitled "Improving Predictability and Transparency in Drug Enforcement Administration (DEA) and Food and Drug Administration (FDA) Regulation." The hearing focused on specific legislation aimed to address issues related to FDA and DEA regulation of drugs and consumer products. Specifically:

  • H.R. 4299, the "Improving Regulatory Transparency for New Medical Therapies Act"
    Chairman Pitts and Ranking Member Pallone introduced H.R. 4299 on March 26, 2014. Currently, new drug products containing substances that previously have not been marketed in the United States and that have abuse potential must be scheduled under the Controlled Substances Act (CSA) by the Drug Enforcement Agency (DEA) prior to being marketed. Under the CSA, there is no deadline for the DEA to make a scheduling decision after receiving a recommendation from the Food and Drug Administration (FDA), and the delays in DEA's decisions have increased significantly. H.R. 4299 would rectify that problem by ensuring DEA acts in a timely manner.
  • H.R. 4069, the "Ensuring Patient Access and Effective Drug Enforcement Act"
    H.R. 4069 was introduced by Representative Marino and Representative Blackburn on March 20, 2014. The bill would help prevent prescription drug abuse while ensuring that patients have access to needed medications by fostering better collaboration between drug manufacturers, wholesalers, pharmacies, DEA and FDA.
  • H.R. 4250, the "Sunscreen Innovation Act"
    Representative Whitfield and Representative Dingell introduced H.R. 4250 on March 13, 2014, as a solution to the current backlog of sunscreen ingredients currently pending at FDA. FDA has not approved a new sunscreen ingredient since the late 1990s, and this bill would reform the process to ensure that new sunscreen ingredients are reviewed in a timely manner.


Panel I
The Honorable Janet Woodcock, M.D.
Director, Center for Drug Evaluation and Research
U.S. Food and Drug Administration

Mr. Joseph T. Rannazzisi
Deputy Assistant Administrator
Office of Diversion Control
Drug Enforcement Administration

Panel II
Dr. Nathan B. Fountain
Medical Advisory Board
Epilepsy Foundation

Mr. John M. Gray
President and CEO
Healthcare Distribution Management Association

Mr. D. Linden Barber
Partner and Director
DEA Compliance Operations
Quarles & Brady

Ms. Wendy K.D. Selig
President and CEO
Melanoma Research Alliance

Mr. Scott Faber
Vice President, Government Affairs
Environmental Working Group

For more information, or to view the hearing, please visit energycommerce.house.gov.

Ways and Means Hearing Examines Final ACA Employer Mandate Requirements

On April 8, 2014, the House Committee on Ways and Means Subcommittee on Health held a hearing to explore the Treasury Department's final employer mandate and employer reporting requirements regulations. The hearing focused on the administration's delays and other changes made to the statutory guidelines and deadlines concerning the employer mandate and reporting requirements.


Mr. J. Mark Iwry
Sr. Advisor to the Secretary and Deputy Assistant Secretary for Retirement and Health Policy
United States Department of the Treasury

For more information, or to view the hearing, please visit waysandmeans.house.gov.


Finance Committee Hearing on FY 2015 HHS Budget Request

On April 10, 2014, the Senate Finance Committee held a hearing on 2015 budget proposals for HHS. HHS Secretary Sebelius, who recently announced her resignation as head of the department, testified that the budget request invests in areas that are critical to long-term prosperity, and also helps address the deficit with legislative proposals that would save an estimated net $356 billion over 10 years. The budget request totals $1.0 trillion in outlays and proposes $77.1 billion in discretionary budget authority, a reduction of $1.3 billion from FY 2014 enacted.

The Honorable Kathleen Sebelius
United States Department of Health and Human Services (HHS)

For more information, or to view the hearing, please visit www.finance.senate.gov.


CMS Reports Increase in Actual Enrollments in Medicaid, CHIP

During the first five months (October through February) of open enrollment, the number of people enrolled in Medicaid or the Children's Health Insurance Program (CHIP) increased by three million. For Medicaid, the increase in enrollment was significantly higher in states that have expanded Medicaid. Those states averaged an 8.3 percent increase in enrollment compared to 1.6 percent in non-expansion states. Of the states expanding Medicaid, Oregon and West Virginia were the states with the largest increase in enrollment, 34.8 percent and 33.5 percent respectively. Health and Human Services Secretary Kathleen Sebelius said HHS expects the enrollment in March to be even higher.

Announcement of Calendar Year (CY) 2015 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter

On April 7, 2014, CMS announced the annual Medicare Advantage (MA) capitation rate for each MA payment area for CY 2015 and the risk and other factors to be used in adjusting such rates. The capitation rate tables for 2015 are posted on the Centers for Medicare & Medicaid Services (CMS) website under Ratebooks and Supporting Data. The statutory component of the regional benchmarks, transitional phase-in periods for the Affordable Care Act rates, qualifying counties and each county's applicable percentage are also posted at this website.

ACA Enrollment Reaches 7.5 Million

Since the Obama Administration extended the enrollment deadline for those who tried to sign up before the March 31 deadline, about 400,000 people have signed up for private health insurance under the Affordable Care Act. This brings the total number of enrollees to 7.5 million. Individuals who tried to sign up before March 31 have until April 15 to complete their applications.

HHS Secretary Sebelius Resigns

Last week, HHS Secretary Sebelius announced she will resign from her post just days after the ACA reached its first-year enrollment goal of seven million enrollees in exchange-based health insurance plans. She spent five years running the Health and Human Services Department, during the critical implementation of President Obama's signature health law. Sylvia Mathews Burwell, director of the Office of Management and Budget, will be nominated to succeed Sebelius. Despite initial glitches in the ACA's rollout, in total, 7.5 million Americans signed up for health insurance coverage through the exchanges, half a million more than some early optimistic estimates.

Medicare Data on Physician Payments Released to Public

According to payment data released by the government on April 9, Medicare paid almost 4,000 doctors and medical professionals more than $1 million each in 2012. Seven doctors received more than $10 million. Eye doctors were among the highest compensated professionals, likely due to new treatments for macular degeneration, the leading cause of blindness in the senior citizens. Internal medicine doctors and cardiologists are also at the top of the list. California and Florida lead the states in receiving the largest payments, with each state getting more than $7 billion from Medicare. Payment records to doctors had not been released to the public for over three decades, until a federal judge lifted the injunction on the data following a lawsuit by Dow Jones & Co. Proponents of the data release hope this information will shed light on fraud and waste by doctors. The American Medical Association is one of the leading opponents, arguing misinterpretation of the data could ruin doctors' careers.

Bill Enacted to Reauthorize Funds for Children's Hospital GME Program

On April 7, President Obama signed into law S. 1557, the Children's Hospital GME Support Reauthorization Act of 2013. The bill reauthorizes the children's hospital graduate medical education (GME) program and provides $300 million in funding through 2018. The Health Resources and Services Administration (HRSA) at the HHS oversees the program. The reauthorization allows HRSA to expand the program by making special payments to certain hospitals that are currently excluded from the Medicare inpatient hospital prospective payment system and whose inpatients are predominantly under 18 years old. The GME program operates at 55 hospitals, and the recipient hospitals train 49 percent of all pediatricians and 51 percent of all pediatric specialists, according to the Children's Hospital Association (CHA). Mark Wietecha, President and CEO of CHA, said the reauthorization "represents a commitment to ensure that children throughout the nation have access to the high-quality care they need and deserve."


Maine Gov. LePage Again Vetoes Medicaid Expansion Bill

On April 10, Maine Gov. Paul LePage again vetoed legislation that would expand Medicaid, as provided for in the ACA. LePage has previously vetoed two similar efforts backed by the state's Democratic-controlled legislature. Consistent with the prior two attempts, the legislature was unable to produce the two-thirds vote to override LePage's veto. LePage has argued that expansion is unaffordable as well as unfair to disabled Mainers currently on a long waiting list for coverage. Expanding the program is estimated to increase Medicaid enrollment by roughly 70,000.


FDA Guidance With Comment Period for Human Compounding Outsourcing Facilities

On April 1, the Food and Drug Administration (FDA) announced the availability of a guidance for industry entitled "Fees for Human Drug Compounding Outsourcing Facilities Under Sections 503B and 744K of the FD&C Act." The guidance is intended for entities that compound human drugs and elect to register as outsourcing facilities (outsourcing facility) under Section 503B of the Federal Food, Drug, and Cosmetic Act (FD&C Act), as added by the Drug Quality and Security Act (DQSA). Entities that elect to register as outsourcing facilities must pay certain fees to be considered outsourcing facilities. This guidance describes the annual establishment fee, the reinspection fee, annual adjustments to fees required by law, how to submit payment, the effect of failure to pay fees and how to qualify as a small business to obtain a reduction of the annual establishment fee. Comments on the draft guidance must be submitted by June 2, 2014.

FDA Proposed Rule on Medical Device Classification Procedures

On March 25, the Food and Drug Administration (FDA) issued a proposed rule to amend its regulations governing classification and reclassification of medical devices to conform to the applicable provisions in the Food and Drug Administration Safety and Innovation Act (FDASIA). FDA is also proposing changes unrelated to the new FDASIA requirements to update its regulations governing classification and reclassification of medical devices. FDA is taking this action to codify the procedures and criteria that apply to classification and reclassification of medical devices and to provide for classification of devices in the lowest regulatory class consistent with the public health and the statutory scheme for device regulation. Comments are due June 23, 2014.

Patient Protection and Affordable Care Act; Exchange and Insurance Market Standards for 2015 and Beyond

On March 14, CMS issued a proposed rule to address various requirements applicable to health insurance issuers, Affordable Insurance Exchanges ("Exchanges"), Navigators, non-Navigator assistance personnel and other entities under the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (collectively referred to as the Affordable Care Act). Specifically, the rule proposes standards related to product discontinuation and renewal, quality reporting, non-discrimination standards, minimum certification standards and responsibilities of qualified health plan (QHP) issuers, the Small Business Health Options Program and enforcement remedies in Federally-facilitated Exchanges. It also proposes: a modification of HHS's allocation of reinsurance contributions collected if those contributions do not meet projections; certain changes to the ceiling on allowable administrative expenses in the risk corridors calculation; modifications to the way CMS calculates certain cost-sharing parameters, rounding those parameters down to the nearest $50 increment; certain approaches CMS is considering to index the required contribution used to determine eligibility for an exemption from the shared responsibility payment under Section CMS-9949-P 2 5000A of the Internal Revenue Code; grounds for imposing civil money penalties on persons who provide false or fraudulent information to the Exchange and on persons who improperly use or disclose information; updated standards for the consumer assistance programs; standards related to the opt-out provisions for self-funded, non-Federal governmental plans and the individual market provisions under the Health Insurance Portability and Accountability Act of 1996; standards for recognition of certain types of foreign group health coverage as minimum essential coverage; amendments to Exchange appeals standards and coverage enrollment and termination standards; and time-limited adjustments to the standards relating to the medical loss ratio program. Comments are due April 18, 2014.

Interim Final Rule - Patient Protection and Affordable Care Act; Third-Party Payment of Qualified Health Plan Premiums

On March 19, HHS issued an interim final rule requiring issuers of qualified health plans (QHPs), including stand-alone dental plans (SADPs), to accept premium and cost-sharing payments made on behalf of enrollees by the Ryan White HIV/AIDS Program, other Federal and State government programs that provide premium and cost-sharing support for specific individuals, and Indian tribes, tribal organizations and urban Indian organizations. Comments will be accepted until May 18; however, the interim final rule is effective as of March 14, 2014.

HHS Proposes Health Information Technology Certification Requirements

On Feb. 26, HHS published a notice of proposed rulemaking to introduce the beginning of the Office of National Coordinator for Health Information Technology's (ONC's) more frequent approach to health information technology certification regulations. Under this approach ONC intends to update certification criteria editions every 12 to 18 months in order to provide smaller, more incremental regulatory changes and policy proposals. The 2015 Edition EHR certification criteria proposed in this rule would be voluntary. No EHR technology developer who has certified its EHR technology to the 2014 Edition would need to recertify to the 2015 Edition in order for its customers to participate in the Medicare and Medicaid EHR Incentive Programs (EHR Incentive Programs). Furthermore, eligible professionals, eligible hospitals and critical access hospitals that participate in the EHR Incentive Programs would not need to "upgrade" to EHR technology certified to the 2015 Edition in order to have EHR technology that meets the Certified EHR Technology (CEHRT) definition. Instead, the 2015 Edition EHR certification criteria would accomplish three policy objectives: 1) They would enable a more efficient and effective response to stakeholder feedback; 2) they would incorporate "bug fixes" to improve on 2014 Edition EHR certification criteria in ways designed to make rules clearer and easier to implement; and 3) they reference newer standards and implementation specifications consistent with promoting innovation and enhancing interoperability.

Comments must be received by April 28, 2014.

FDA Public Docket for Interoperable Rx Tracking System

FDA has established a public docket to receive information and comments on standards for the interoperable exchange of information associated with transactions involving human prescription drugs in a finished dosage form (prescription drugs) to comply with new requirements in the Drug Supply Chain Security Act (DSCSA). FDA is seeking information from drug manufacturers, repackagers, wholesale distributors, dispensers (primarily pharmacies) and other drug supply chain stakeholders and interested parties, including standards organizations, State and Federal agencies, and solution providers. In particular, stakeholders and other interested parties are requested to comment about the interoperable exchange of transaction information, transaction history and transaction statements, in paper or electronic format, for each transfer of product in which a change of ownership occurs. This action is related to FDA's implementation of the DSCSA. Comments are due April 21, 2014.

IRS, HHS, DOL: Guidance Issued with Final Proposed Rules on 90-Day Waiting Periods Under ACA

On Feb. 20, the Internal Revenue Service (IRS), Department of Health and Human Services (HHS) and Department of Labor (DOL) released their final proposed rule clarifying the relationship between a plan's eligibility criteria and the 90-day waiting period limitation. In order to be in compliance with the Affordable Care Act (ACA), in the rule, insurers offering group health insurance coverage cannot institute a waiting period that surpasses 90 days. The final rule, which goes into effect on April 25, applies to plan years starting Jan. 1, 2015, or after. "This is a common sense measure that helps workers access employer-sponsored health insurance while providing employers flexibility," said DOL's Assistant Secretary of Employee Benefits Security Administration Phyllis C. Borzi. Also of note, the rule limits the maximum allowed length for the employment-based orientation period to no more than one month. Comments on the proposed rules are due by April 25, and the rule is expected to be published in the Federal Register on Feb. 24.


Medicare: Second Year Update for CMS's Durable Medical Equipment Competitive Bidding Program Round 1 Rebid

According to a recently released report by GAO studying the impact of the Medicare competitive bidding program (CBP) for durable medical equipment (DME), the round 1 rebid's first two years achieved Medicare cost savings of about $400 million as estimated by CMS, and did not appear to have adversely affected beneficiary access to CBP-covered items. However, with CBP's national mail-order diabetic testing supplies program and expansion into an additional 100 bidding areas in July 2013, it will be important for CMS to continue its efforts to monitor the effects of the CBP. In addition, the total number of DME suppliers and Medicare-allowed charges decreased more in the CBP areas than in the comparator areas. For example, the number of suppliers in the CBP areas with Medicare-allowed charges of $2,500 or more decreased, on average, 27 percent, whereas in the comparator areas, supplier numbers decreased by 5 percent.

HHS-OIG: Limited Compliance with Medicare's Home Health Face-to-Face Documentation Requirements

According the HHS-OIG, for 32 percent of home health claims that required face-to-face encounters, available documentation did not meet requirements under the program necessary to justify payment for services rendered, resulting in $2 billion in payments that should not have been made. Furthermore, physicians inconsistently completed the narrative portion of the face-to-face documentation. Some face-to-face documents provide information that, although not required by Medicare, could be useful, such as a printed name for the physician and a list of the home health services needed. CMS oversight of the face-to-face requirement is minimal. The OIG recommends that CMS (1) consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation, (2) develop a specific strategy to communicate directly with physicians about the face-to-face requirement and (3) develop other oversight mechanisms for the face-to-face requirement. CMS concurred with all three of these recommendations.

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.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Similar Articles
Relevancy Powered by MondaqAI
In association with
Related Topics
Similar Articles
Relevancy Powered by MondaqAI
Related Articles
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions

Mondaq.com (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of www.mondaq.com

To Use Mondaq.com you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions