In its campaign against the corruption of medical decision making and illegal kickbacks, the Department of Justice (“DOJ”) has increasingly come to rely upon two pieces of legislation together with the Federal Anti-Kickback Statute (“AKS”):... Read More
If your organization is challenged by the limitations on physician compensation imposed by the Stark Law (“Stark”) and the federal Anti-Kickback Statute (“AKS”), a Value Based Enterprise (“VBE”) may provide relief from those constraints.... Read More
Last month, several pharmacies participating in a major PBM’s networks received notices about their Hub relationships. Pharmacies were reminded of their inability to enter into Hub arrangements without prior consent from the PBM and were directed... Read More
Earlier this month, the DOJ announced that a pharmacy owner pleaded guilty to conspiracy to commit health care fraud for his involvement in an $8.3 million scheme. The individual was an owner of three pharmacies that paid kickbacks to telemarketers... Read More
Earlier this month, the Department of Health and Human Services Office of Inspector General (“OIG”) released a data brief that identified potential concerns of fraud, waste, or abuse in telehealth services delivered during the first year of the... Read More
In a case involving allegations of fraudulent billing of Medicare/Medicaid for invalid, unlawful and medically unnecessary prescriptions using collaborative practice agreements (CPAs), three Florida compounding pharmacies settled with the Department... Read More
The National Cancer Institute (NCI), a part of the National Institutes of Health (NIH), selected four academic institutions to award $23 million to establish centers of excellence to research delivery of cancer-related care through telehealth. The... Read More
Last week, the House of Representatives passed an act to extend Medicare telehealth flexibilities after the conclusion of the Public Health Emergency (“PHE”). The “Advancing Telehealth Beyond COVID–19 Act of 2022” (“Act”) aims to... Read More
The Office for Civil Rights (OCR) recently announced the resolution of eleven investigations in its Health Insurance Portability and Accountability Act (HIPAA) Right of Access Initiative, bringing the total number of enforcement actions to... Read More
On July 20, 2022, the Office of Inspector General (OIG) issued a Special Fraud Alert warning practitioners to exercise caution when entering into certain telehealth arrangements. The Alert references the many recent investigations of telemedicine... Read More