Articles and Blogs

In an effort to not only establish a uniform standard for how U.S. Attorney Offices (“USAOs”) assess and credit voluntary self-disclosures but to also incentivize early and voluntary self-disclosure of corporate criminal misconduct, the Department of Justice (“DOJ”) has implemented a new Voluntary Self-Disclosure (“VSD”) Policy to be used by USAOs nationwide (the “Policy”).... READ MORE

On June 16, 2017, CMS issued transmittal S&C: 17-35-ALL. This transmittal clarified CMS policy by stating a reasonable assurance period will apply if a provider or supplier voluntarily terminates its Medicare certification when an enforcement action has been initiated by the State Survey Agency. Section 2016 of the State Operations Manual allows a provider... READ MORE