Publications by T. James Junger

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Executive Order Creates Potential False Claims Act Liability for Employment Discrimination

[01/31/25]

HHS Cannot Exclude § 1115 Waiver Days from Medicare DSH Formula

[08/22/24]

HHS Publishes Its Final 340B ADR Regulation

[04/18/24]

CMS Releases Repayment Proposal for 340B Payment Cuts

[07/07/23]

Hospitals Have Until March 23 to Object to Release Provider Relief Fund High Impact Data

[03/14/23]

"Top Ten Issues in Health Law 2023." AHLA Health Law Connections, January 2023.

[01/01/2023]

CMS Proposes Changes to Graduate Medical Education in 2023 IPPS Proposed Rule

[05/20/22]

Have a Plan for Planned Giving: Funds Being Donated Not a Factor in Fraud and Abuse Analysis

[02/25/22]

Many Teaching Hospitals May Benefit from New GME Rules

[01/12/22]

CMS Issues Final Rules Implementing GME Provision of the CAA: Part 5 of Our Series on Graduate Medical Education

[01/12/22]

Higher Minimum Penalties and Other Important Updates to the OIG’s Health Care Fraud Self-Disclosure Protocol

[11/12/21]

Teaching Physician and Teaching Hospital Changes in the Proposed 2022 Medicare Part B Payment Policies Rule

[07/30/21]

COVID Relief Act Brings New Cap Space and Other Good News for Teaching Hospitals: Part 3 of Our Series on Graduate Medical Education in 2021

[03/15/21]

"Telemedicine after COVID-19: What happened and what's next?" HCCA, March 2021.

Hospitals Beware: New OIG Report Suggests Rampant Inpatient Upcoding

[03/01/21]

HHS Advisory Opinion: Drug Manufacturers Must Offer 340B Program Discounts to Contract Pharmacies

[02/25/21]

Temporary and Permanent Changes to PATH Billing and FTE Cap Transfers: Part 2 of Our Series on Graduate Medical Education in 2021

[01/29/21]

Moonlighting and Redocumentation: Part 1 of Our Series on Graduate Medical Education in 2021

[01/15/21]

OIG Issues New Guidance Regarding Big-Box Store Gift Cards as Patient Incentives

[01/08/21]

"340B Program in the Crosshairs: What the Next Few Months May Bring." AHLA, November 2020.

You Can Take It With You: CMS Finalizes GME Cap Transfer Rule

[09/04/20]

What Do You Want from Me? HHS’s Proposed Rule on Guidance Documents Would Clarify Agency Expectations

[08/19/20]

Objectively Reasonable Interpretation Saves Pharmacies from FCA Liability

[07/14/20]

Graduate Medical Education in Health Care M&A: Four Things You Need to Know

[07/09/20]

False Claims Cost More: DOJ Increases Civil Penalties for False Claims Act Violations

[07/01/20]

GME Cap Space Travels Easier Under 2021 IPPS Proposed Rule

[06/01/20]

CMS Stabilizes Graduate Medical Education Payments in COVID-19 Rule and Extends Deadlines for FTE Cap Agreements

[05/29/20]

OIG Strategic Plan Announces Priorities for COVID-19 Enforcement

[05/28/20]

"Compliance Priorities in Practice Acquisitions." Compliance Today, May 2020.

DOJ’S 2019 False Claims Act Recoveries Total More Than $3 Billion

[01/15/20]

"Juicing with Friends: Compliance Lessons from Baseball’s Steroid Era." Journal of Health Care Compliance, November/December 2019.

CMS Finalizes New Anti-Fraud Tools Aimed at Affiliations

[09/10/19]

A New Option for Grant Noncompliance: OIG Releases Grantee Self-Disclosure Program

[08/16/19]

"Yates Memo 2.0: Recent Revisions Grant More Discretion for the DOJ to Interpret Individual Accountability Standards." The Health Lawyer, April 2019.

Department of Justice Updates Compliance Program Guidance

[05/13/19]

CMS Updates Preclusion List Requirements for Medicare Advantage and Part D

[05/10/19]

"Securing the safety net: Current compliance issues in Federally Qualified Health Centers." CT Magazine, May 2019.

"CMS Preclusion List Now in Effect," State Bar of Wisconsin, April 2019.

Claims Denials Start April 1: What You Should Know About CMS’s New Preclusion List

[02/15/19]

"A Seismic Shift for Providers: The Eliminating Kickbacks in Recovery Act." State Bar of Wisconsin, February 2019.

Department of Justice Announces Important Updates to Yates Memo Requirements

[12/07/18]

"The Past is Prologue: Reviewing Compliance Landmarks from 2018 to Plan for 2019," Compliance Today, December 2018.

Are You In or Are You Out? Inpatient Admission Status Is a Key Risk Area for Medicare Providers

[04/26/18]

Update: Wisconsin Supreme Court Treats Non-Solicitation of Employees Clause as a Restrictive Covenant

[01/26/18]

Arbitration Agreement Not Binding on Whistleblower, Says Ninth Circuit

[09/15/17]

Wisconsin Supreme Court to Decide Limits on Non-Solicitation of Employee Clauses

[09/05/17]

Hall Render AHLA Briefing on Compliance Program Effectiveness

[06/22/17]

But Does It Work? OIG Resource Guide Provides Clarity on Measuring Compliance Program Effectiveness

[03/27/17]

What Did Leaders Know and When Did They Know It? New DOJ Guidance Offers Key Insights on Effective Compliance Programs

[03/09/17]

New AKS Safe Harbors Create Opportunities for Providers

[12/08/16]

Deadline Looming for Applications for CMS’s Comprehensive Primary Care Plus Payment Model

[08/29/16]

340B Program House Subcommittee Testimony: Overview and Insights

[03/30/15]

Additional Guidance on the Premium Support Conundrum

[06/16/14]