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HHS-OIG Corporate Integrity Agreements Are Now Aiming at Corporate Directors and Executives

Corporate integrity agreements (CIAs) are a familiar feature of many civil False Claim Act and joint civil/criminal resolutions in healthcare fraud cases. These agreements are entered into between the defendant company and...more

Organizations Receiving Payments from New York State May be Subject to New Limits on Executive Compensation

The State of New York has enacted new regulations limiting executive compensation for covered providers of services paid for by “State funds” and “State-authorized payments.” ...more

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

Navigating the Provider Self-Disclosure Protocol

Providers can voluntarily disclose potential fraud with respect to Federal health care programs — Medicare, Medicaid, and potentially private insurers to the extent Federal or state funds are involved — by following the...more

Mandatory Compliance Programs for Healthcare Companies

The healthcare industry always has taken the lead in compliance issues, developing innovative compliance tools and programs. Anti-corruption compliance borrows heavily from many healthcare compliance ideas....more

False Claims Act Compliance and Health Care

Doctors and health care service providers are under the False Claims Act microscope. The risks are significant and the costs can be astronomical. For all the obvious risks, doctors, hospitals, PPOs, HMOs, and health care...more

"Violations of Corporate Integrity Agreement Trigger Divestiture Action by HHS OIG"

In a little-noticed decision, the Office of the Inspector General of the Department of Health and Human Services (OIG) has forced a company that violated its corporate integrity agreement (CIA) to divest a subsidiary as a...more

OIG Advisory Opinion 12-06 Disapproves of Proposed Arrangements Between ASCs and Anesthesia Services Providers

In OIG Advisory Opinion 12-06, the OIG determined that two proposed arrangements between an anesthesia services provider (the “Requestor”) and professional corporations (“PCs”) or limited liability companies (“LLCs”) that own...more

Cuomo Issues Executive Order Regarding Limits on Executive Compensation

After withdrawing nearly identical proposed legislation one day earlier, on January 18, 2012, New York Governor Andrew Cuomo issued an Executive Order directing certain New York State agencies, including the Department of...more

ACOs, Bundled Payments, and the Specialist Physician

Orthopedic surgeons, like all specialists, need a steady flow of referrals, and adequate reimbursement for services. Health reform is making it harder to succeed. We all need to get smart about ACOs and other shared savings...more

One Year Later: The Impact of Health Care Reform on Health Care Provider Audits and Compliance Programs

The Patient Protection and Affordable Care Act (PPACA) expands the breadth and depth of Medicare and Medicaid contractor oversight into provider and supplier medical practices. It further requires formal complicance plans of...more

It’s Not Just the Conviction — It’s Also the Consequences

Attention: top executives in the healthcare industry. Take heed, or you could be forced to seek employment in a different industry, as three former top executives at Purdue Pharma recently found out. In May 2007, Purdue...more

Federal Forecaster: Relevant News For Entities & Individuals With Business Concerns in the Areas of Government Contracts & Grants...

IN THIS ISSUE: - Suspension and Debarment Is Not a Tool To Punish…Except When It Is — Page 2 - Don’t Forget About D&O Insurance When That Government Subpoena Arrives — Page 5 - New Service Contracting Regulations: Will...more

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