Within just weeks of each other, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) issued separate documents that health care organizations may use to...more
4/21/2017
/ Compliance Management Systems ,
Corporate Governance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Health Care Providers ,
Healthcare Fraud ,
Investigations ,
OIG ,
Policies and Procedures ,
Resource Guide ,
Third-Party Relationships
The Supreme Court of the United States in Universal Health Services, Inc. v. Escobar et al., weighed in on and embraced the implied certification theory of liability within the False Claims Act (FCA)....more
6/22/2016
/ False Claims Act (FCA) ,
False Implied Certification Theory ,
Federal Contractors ,
Health Care Providers ,
Implied Certification ,
Material Misrepresentation ,
Medicaid ,
Medicare ,
Mental Health ,
SCOTUS ,
Universal Health Services Inc v United States ex rel Escobar ,
Unlicensed Medical Providers
On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged...more
The Department of Health and Human Services Office of Inspector General (HHS-OIG) recently released its FY 2016 Work Plan, in which it identified key areas of focus for the upcoming year. Consistent with its mandate to detect...more
In today’s robust enforcement climate, most companies have taken at least the first steps towards establishing a formal corporate compliance program. The mere existence of such a program, however, will not by itself protect a...more
A federal court has ordered discovery regarding the circumstances of a Medicare payment suspension by CMS only one week after failed settlement negotiations between a cardiology practice and the Department of Justice (DOJ) to...more
6/16/2015
/ Centers for Medicare & Medicaid Services (CMS) ,
Department of Justice (DOJ) ,
Discovery ,
False Claims Act (FCA) ,
Fraud ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Preliminary Injunctions ,
Provider Payments ,
Retaliation ,
Suspensions