Articles
Fraud and Abuse Compliance Review No. 2: Fair Market Value and Commercially Reasonable
(Author’s/Editor’s note: This will be a series of articles addressing Fraud & Abuse) Every financial relationship a hospital has with a physician or physician owned entity must be reviewed and structured to ensure it complies …..
Fraud and Abuse Compliance Review No. 1: Physician Services Agreements
With the federal government’s stated goal to help pay for the coming healthcare reform package through increased fraud and abuse enforcement, it is imperative hospitals conduct a compliance review of their contractual arrangements with physicians …..
Changes to False Claims Act Present Greater Risks to Healthcare Providers
The Civil False Claims Act (FCA), 31 U.S.C. §3729, has long been an effective weapon for the federal government in combating fraud and abuse in government contracting. The Office of Inspector General (OIG) for the …..
Significant Changes to Stark II Exceptions Go Into Effect October 1, 2009
Healthcare reform has never been so much in the forefront of the public’s mind. However, with all of the discussion focused on broad overarching policy goals, it is easy to forget that the Centers for …..
Hospitals Need to Prepare Now for CMS’ New Stark Compliance Audits
Executive Summary The Centers for Medicare and Medicaid Services (CMS) is planning, for the first time, to actively police Stark II compliance by sending out disclosure forms to 500 hospitals requiring the hospitals to disclose …..
Life after Boren: The New Public Process and the Resurgence of Equal Access to Care
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