During the American Bar Association’s 39th National Institute on White Collar Crime, the most senior executives of the DOJ (Attorney General Merrick B. Garland and Deputy Attorney General Lisa Monaco) delivered remarks...more
HHS sent notices to noncompliant physicians and facilities on March 10, 2022 giving them 30 days to return funds paid to healthcare providers who have not complied with the agency’s reporting requirements....more
There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas:
..The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as...more
1/20/2022
/ Audits ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Personal Liability ,
Physicians ,
Relief Measures ,
Yates Memorandum
In the August 12, 2021 MLN Connects News, CMS announced resumption of TPE Program.
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On September 9, 2015, Sally Quillar Yates, Deputy Attorney General of the Department of Justice (DOJ) issued a memo entitled “Individual Accountability for Corporate Wrongdoing” to address the issue of incentivizing...more
U.S. Department of Health and Human Services Office for Civil Rights (OCR) recently announced yet another enforcement action. Specifically, OCR opened a compliance review of Concentra Health Services (Concentra) upon...more
Attorneys routinely advise clients conducting audits and investigations that the audit or investigation should be conducted by outside counsel in order to establish attorney client privilege.
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In OIG Advisory Opinion No. 13-03, the Office of Inspector General had the opportunity to deal with two issues which have always raised concerns in the past, i.e. pod labs and swapping. It is no surprise that OIG refused to...more