As previously discussed in our article in June 2022, the New York Department of Health (“NYDOH”) has taken the position that community pharmacies that have dual enrollment with Medicare as both a pharmacy provider (through CMS-855B enrollment)... Read More
On February 22, 2023, the U.S. Department of Justice (“DOJ”) issued a corporate Voluntary Self-Disclosure policy (the “Policy”) that applies to all United States Attorney’s Offices (“USAOs”), effective immediately. The articulated goal... 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
The shifting of services to outpatient settings will likely cause hospitals to unwind their contractual relationships with cardiologists, sending the physicians back into private practice. Astute hospital administrators will have already anticipated... Read More
A Value-Based Enterprise (VBE) is an underutilized mechanism for meeting a stark exception or anti-kickback statute safe harbor. If your organization is challenged by the limitations on physician compensation imposed by the Stark Law and the federal... Read More
Specialty dental practices can be attractive targets for private equity investors. Conversely, the sale of a dental practice to a private equity (or private equity-backed) organization can be an effective way to maximize the value of a specialty... Read More
The Department of Justice (“DOJ”) recently established the Elder Justice Initiative (“EJI”), which directs Government efforts to combat elder abuse, neglect, and financial fraud. The EJI seeks to address several schemes affecting older... Read More
Licensees who have been the subject of an adverse legal action, such as a criminal charge, State licensing disciplinary matter, or adverse credentialing action, have a duty to report such action. The time limit for reporting varies. As such, it is... Read More
On December 16, 2021, the Department of Health and Human Services, Office of Inspector General (“OIG”) issued a report analyzing nationwide trends in genetic tests for which payments were made under Medicare Part B. The OIG report follows a... Read More
Last month, a Joint Stipulation of Dismissal was filed on behalf of a home health service provider and its affiliated entities settling a qui tam action for violations of the Federal False Claims Act ( “FCA”). The defendants submitted claims... Read More
