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Tom Crane

Tom Crane

Mintz Levin


Latest Publications

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OIG Issues Updated Self-Disclosure Protocol

The Department of Health and Human Services Office of Inspector General (“OIG”) has published an updated Provider Self-Disclosure Protocol (the “Updated SDP”) that offers health care providers guidance on how to disclose...more

4/18/2013 - Anti-Kickback Statute Civil Monetary Penalty Healthcare OIG Overpayment Self-Disclosure Requirements

CMS Focuses on Fraud Associated with Increased Use of Electronic Health Records

Acting CMS Administrator, Marilyn Tavenner, recently reaffirmed the agency’s concern that the increased use of electronic health records (“EHRs”) has contributed to increases in fraudulent billing practices by providers. At a...more

3/22/2013 - Audits CMS Electronic Medical Records False Billing Fraud Healthcare

CMS Publishes Final Sunshine Act Rule Creating New Regulatory Landscape for Physician-Manufacturer Interactions

Originally published in the Health Care Fraud Report, 17 HFRA 219, on 03/06/2013. The final rule (the ‘‘Final Rule’’) implementing the Physician Payments Sunshine Act (‘‘Sunshine Act’’), published in the Federal...more

3/7/2013 - CMS Drug Manufacturers Joint Purchasing Programs Physicians Sunshine Act

Let the Collection and Reporting Begin: CMS Publishes Final Sunshine Act Regulations

The long-awaited final rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act) has arrived at the Federal Register. It amends key definitions and adds new terms; retains broad reporting...more

2/4/2013 - Biologics CME CMS Data Collection Drug Manufacturers GPOs Medical Devices Pharmaceutical Reporting Requirements Stark Law Sunshine Act

GAO Targets Self-Referred Advanced Imaging Services

In a recently issued GAO Report entitled, “Higher Use of Advanced Imaging Services by Providers Who Self-Refer Costing Medicare Millions,” the Government Accountability Office (GAO) identified significant utilization trend...more

11/19/2012

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