Amy Garrigues

Amy Garrigues

K&L Gates LLP

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Bonuses for Physician Employees: Lessons Learned from the Halifax Hospital Case

This week, a federal district court in Florida concluded that a hospital violated Stark as a matter of law by entering into employment agreements with physicians that included bonus compensation that was not based exclusively...more

11/22/2013 - Bonuses Healthcare Medicare Patient Referrals Physicians Profit Sharing Stark Law

CMS Issues New Guidance on 2-Midnights Standard and Delays Audits

Centers for Medicare and Medicaid Services (CMS) finalized a new rule, effective October 1, 2013, under which hospital inpatient admissions are considered reasonable and medically necessary if the physician expects a...more

11/18/2013 - Admissions CMS Healthcare IPPS MACs

Sending the Privilege Away: Attorney-Client E-Mails in the Corporate Setting

In a pending False Claims Act (“FCA”) case involving allegations of noncompliance with the federal physician self-referral law (the “Stark Law”), 42 U.S.C. § 1395nn, the United States District Court for the Middle District of...more

1/8/2013 - Attorney-Client Privilege Corporate Counsel Crime-Fraud Exception Email False Claims Act Stark Law Whistleblowers Work Product Privilege

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