The U.S. Department of Health and Human Services Office of the Inspector General is looking for ways to encourage and incentivize coordinated care, without violating the Anti-kickback Statute and Civil Monetary Penalties Law. The CMP imposes penalties against those who offer or transfer remuneration to a Medicare or state healthcare program beneficiary to influence the…

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In an attempt to streamline the self-disclosure process, The Centers for Medicare and Medicaid Services (CMS) recently posted revisions to the Voluntary Self-Disclosure Protocol (SRDP), which allows providers of healthcare services and suppliers to self-disclose actual or potential violations of the federal physician self-referral law. Beginning June 1, providers of services and suppliers must use…

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The Centers for Medicare and Medicaid recently published a notice proposing revisions to its self-referral disclosure protocol (SRDP). The SRDP allows healthcare providers and suppliers to self-disclose actual or potential violations of the physician self-referral statute, or Stark Law. Under the proposal, healthcare providers who use the SRDP will have to provide the agency with…

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The federal government has been busy since the beginning of the year announcing arrests, convictions and settlements relating to healthcare fraud and abuse. The activities relate to violations of the Stark Law, anti-kickback law and federal False Claims Act, and there appears to be no end in sight. Whether it’s home health, transportation, durable medical…

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In the last year or so there have been a number of stories in the media about investigations into wrongdoing by compounding pharmacies, marketing companies and physicians. At last count there were nearly 100 federal investigations underway for what the feds believe are questionable financial relationships involving these three entities. In some instances, physicians are…

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