David Glynn

David Glynn

Holland & Knight LLP

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FCA 60-Day Repayment Provision Runs from Discovery of Potential Overpayment

The U.S. District Court for the Southern District of New York issued the first decision directly addressing when an overpayment is “identified” for purposes of starting the 60-day repayment clock under the federal False...more

8/12/2015 - Affordable Care Act Billing Civil Investigation Demand Compliance False Claims Act FERA Healthcare Healthcare Providers Medicaid Medicare Overpayment Overpayment Recovery Time Limits

CMS Announces Final Regulatory Changes to Medicare Advantage and Part D

- CMS issues final Medicare Advantage and Part D regulatory changes after a controversial proposed rule was announced earlier this year. - New requirements for the reporting and return of Medicare Advantage and Part D...more

6/5/2014 - CMS Final Rules Healthcare Medicare Medicare Advantage Medicare Part D Overpayment Pharmaceutical Pharmacies Prescription Drugs

Healthcare IT News: OIG Does An About-Face On Referral Service Pricing

The Department of Health and Human Services Office of Inspector General (OIG) recently terminated a favorable 2011 advisory opinion regarding a healthcare IT company's "per-click" pricing model for its provider referral...more

4/17/2014 - Health Information Technologies Healthcare OIG Patient Referrals

Is Filling an Off-Label Prescription an Invitation to False Claims Act Liability?

On May 17, 2013, the U.S. District Court for the Northern District of Georgia issued an order that joins an unsettling line of decisions suggesting that before filling prescriptions, pharmacies must serve as the arbiters of...more

6/10/2013 - False Claims Act Healthcare Professionals Medicare Medicare Part D Off-Label Promotion Off-Label Use Prescription Drugs

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