Thomas Crane on Anti-Kickback Statute

7th Circuit Court of Appeals Creates Expansive Definition of “Referral” Under the Anti-Kickback Statute

On February 10, 2015, in United States v. Patel (Case No. 14-2607), the Seventh Circuit Court of Appeals ruled that a physician makes a “referral” within the meaning of the federal health care programs Anti-Kickback Statute...more

2/12/2015 / Anti-Kickback Statute , Appeals , Home Health Care , Medicare , Patient Referrals , Physicians

GPO Fees Under Scrutiny by the GAO

Last week, the Government Accountability Office (GAO) released a report examining group purchasing organization (GPO) practices. The GAO questioned whether the current structure of GPO funding through administrative fees is...more

12/5/2014 / Anti-Kickback Statute , Department of Health and Human Services (HHS) , GAO , GPOs , Hospitals , Processing Fees , Reporting Requirements , Revenue , Safe Harbors

Proposed Rule Issued by OIG Realigns Its Enforcement Views with Health Care Reform Goals

Fridays never seem to be slow in the health care regulatory world. On Friday, October 3rd, the HHS Office of the Inspector General (OIG) issued a highly anticipated proposed rule (the Proposed Rule) that provides amendments...more

10/10/2014 / Ambulance Providers , Anti-Kickback Statute , Cost-Sharing , Medicare Part D , OIG , Proposed Regulation , Safe Harbors

Another Court Weighs in on Rule 9(b)’s Requirements Under the False Claims Act

A federal district court recently dismissed a qui tam relator’s complaint in a declined case against the Hospital for Special Surgery (“Hospital”), its former CEO, and an outside billing company alleging that they violated...more

8/28/2014 / Anti-Kickback Statute , False Claims Act (FCA) , Hospitals , Qui Tam , Rule 9(b) , Stark Law

CMS Declares Third Party Payment of QHP Premiums Not OK

On the heels of HHS’s recent announcement that qualified health plans (QHPs) purchased through the Affordable Care Act (ACA) insurance exchanges are not “federal health care programs” for purposes of the federal anti-kickback...more

11/6/2013 / Affordable Care Act , Anti-Kickback Statute , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Premiums , Qualified Health Plans , Third-Party

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

Thomas Crane

Mintz

Popular Topics by This Author

Latest Posts › Anti-Kickback Statute

7th Circuit Court of Appeals Creates Expansive Definition of “Referral” Under the Anti-Kickback Statute

GPO Fees Under Scrutiny by the GAO

Proposed Rule Issued by OIG Realigns Its Enforcement Views with Health Care Reform Goals

Another Court Weighs in on Rule 9(b)’s Requirements Under the False Claims Act

CMS Declares Third Party Payment of QHP Premiums Not OK

OIG Issues Updated Self-Disclosure Protocol

Thomas Crane

Mintz

Popular Topics by This Author

Latest Posts › Anti-Kickback Statute

7th Circuit Court of Appeals Creates Expansive Definition of “Referral” Under the Anti-Kickback Statute

GPO Fees Under Scrutiny by the GAO

Proposed Rule Issued by OIG Realigns Its Enforcement Views with Health Care Reform Goals

Another Court Weighs in on Rule 9(b)’s Requirements Under the False Claims Act

CMS Declares Third Party Payment of QHP Premiums Not OK

OIG Issues Updated Self-Disclosure Protocol

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