CMS and OIG Announce Plan To Exclude “Recalcitrant Providers”

In a move that made little immediate splash, but has since received considerable media attention, including a recent article in the New York Times, the Department of Health & Human Services announced that it will take additional steps against “recalcitrant providers,” including exclusion from participation …

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The Wrinkle In Dinkel: The Departmental Appeals Board (Re)Defines the “Should Have Known” Standard for Exclusion Actions Under 1128(b)(7)

In a recent application of the Exclusion Statute, Social Security Act § 1128 et seq., the Department of Health & Human Services Departmental Appeals Board (Board) clarified that providers have an affirmative obligation to understand and correctly apply Medicare billing rules.  In doing so, the Board arguably …

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