Articles and Blogs

Historically, health care entities looking to avoid potential violations under the Federal Stark Law (“Stark”) have not turned to the Payments by a Physician exception at 42 C.F.R. § 411.357(i) to protect their operations. A review of the exception’s history, however, combined with recent experience with pending submissions to the Centers for Medicare &... READ MORE

On June 9, 2022, the Centers for Medicare & Medicaid Services (“CMS”) published a notice seeking public comment on its plan to revise the way information is collected under its voluntary Self-Referral Disclosure Protocol (“SRDP”). Specifically, the proposed rule would allow a group practice to submit a single “Group Practice Information Form” that would cover all... READ MORE

The DOJ’s recent revisions to its Justice Manual created a new path for self-disclosing potential fraud to the government – one which is unique in its ability to defray the costs of potential False Claims Act violations. In 2015, Deputy Attorney General Sally Quillian Yates released a memo entitled Individual Accountability for Corporate Wrongdoing, more... READ MORE