Physicians Civil Monetary Penalty

News & Analysis as of

The Corporate Practice Prohibition in New York: What We Can Learn From the ADMI Settlement

One of the most frequently asked questions posed to healthcare lawyers is whether State X has a prohibition on the corporate practice of medicine, nursing or other profession, and if so, whether the prohibition is enforced. ...more

Physicians Face Increased Anti-Kickback Enforcement Focus

It appears that the Office of Inspector General (“OIG”) now has physicians squarely in the crosshairs of one of its most powerful enforcement tools: the Anti-Kickback Statute (“AKS”). The AKS is a criminal statute with...more

HHS Issues Fraud Alert on Medical Directorship Relationships - Hospitals and Physicians Need to Review Agreements to Prevent a...

On June 9, 2015, the U.S. Department of Health and Human Services Office of the Inspector General (OIG) released a Fraud Alert regarding recent settlements with 12 individual physicians who were party to questionable medical...more

SGR Fix Bill Includes Important Change to Gainsharing CMP

President Obama recently signed into law Public Law No. 114-10, the “Medicare Access and CHIP Reauthorization Act of 2015” (P.L. 114-10), which overhauls Medicare physician reimbursements by eliminating the use of the...more

Medicare Access and CHIP Reauthorization Act: Paving the Way for Broader Gainsharing Activities

On April 16, 2015, President Obama signed into law H.R.2, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), a critical piece of health care legislation which represents significant movement towards a health...more

Health Care Enforcement in 2015: A Look Back on 2014 and Forecasting the Year Ahead

In testimony before the House Oversight and Government Reform Subcommittee on Health Care in April 2011, the now-pending nominee for U.S. Attorney General, Loretta E. Lynch, stated in no uncertain terms that “fighting health...more

OIG Approves Co-Management Arrangement

Hospitals across the country have been actively seeking to align physician interests with the interests of the hospital, in order to provide high quality patient care in a more coordinated and efficient manner. Many hospitals...more

OIG Advisory Opinion Sheds Light On Pay-For-Performance Relationships Between Hospitals And Physicians

On January 7, 2013, the HHS OIG released Advisory Opinion 12-22 concerning a rural hospital's (Hospital) proposal to pay a cardiology group (Group) a performance bonus for achieving certain patient service, quality and cost...more

OIG: Cardiac Catheterization Arrangement Between Hospital and Physicians Not Subject to Sanctions

On January 7, 2013, HHS OIG published a favorable advisory opinion on a management arrangement between a hospital and a cardiology group related to the provision of certain cardiac catheterization services at the hospital. ...more

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