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Health Care Enforcement: “Tea Leaves” in the 2024 National Health Care Fraud Summer Takedown

Each summer in recent years, the U.S. Department of Justice (DOJ) and associated fraud enforcement partners have indicted many health care defendants, in multiple cases across the country. This summer continued the tradition....more

“Let’s Talk Compliance”: OIG’s General Compliance Program Guidance: How to Refresh Compliance Programs

Editor’s Note: PYA and Foley & Lardner hosted the 6th Annual “Let’s Talk Compliance” two-day Virtual Conference on January 18 and 19, 2024. Panelists included Foley & Lardner attorneys and PYA experts. The event was hosted by...more

HHS OIG: New “General Compliance Program Guidance” Provides Voluntary Steps Towards Increased Effectiveness

In connection with the November 2023 Health Care Compliance Association’s (HCCA) Healthcare Enforcement Compliance Conference, and with acknowledgment by the Chief Counsel to the Inspector General, Rob DeConti, of the long...more

District Court Allows Derivative Advice of Counsel in Support of Good Faith Defense

On June 3, 2021, the Northern District of Texas ruled on a novel issue in U.S. v. Hagen (Case No. 3:19-CR-0146-B (N.D. Tex.)). In a health care fraud conspiracy case against DME suppliers, the court held that a good faith...more

Ambulance Suppliers: CMS Is Not Planning to Issue Fraud Waivers for ET3

On February 14, 2019, CMS’ Innovation Center announced its Emergency Triage, Treat, and Transport (ET3) Model for EMS / ambulance suppliers to partner with other health care providers such as telehealth entities and urgent...more

CMS Revokes Billing Privileges for Competitive Bid Supplier

The Centers for Medicare and Medicaid Services (CMS) has demonstrated that it will not hesitate to use one of its most crippling administrative enforcement tools—the revocation of Medicare billing privileges—against one of...more

Medicare's Fraud Prevention System: CMS Issues Second-Year Report to Congress

The Small Business Jobs Act of 2010 (pertinent sections of which are codified at 42 U.S.C. Section 1320a-7m) directed the Centers for Medicare & Medicaid Services (CMS) to use predictive modeling and other analytics...more

OIG Releases Report on Medicaid Fraud Control Units

The Department of Health and Human Services (HHS) Office of Inspector General (HHS-OIG) has released its Fiscal Year (FY) 2013 Annual Report (Report) on the performance of the Medicaid Fraud Control Units (MFCU)...more

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