Two decisions were issued this past week in a district that handles a large number of qui tam actions. The United States District Court in Boston issued decisions that will help demarcate the point where conduct is too attenuated from the submission of a claim to form a potential basis for False Claims Act …
Caught by the CIA: Corporate Integrity Agreement Violation is Grounds for False Claims Act Liability
March 7, 2012 Leave a Comment
In a decision with potentially significant implications, the U.S. Court of Appeals for the Eleventh Circuit ruled on February 22, 2012, that the failure to satisfy reporting and monitoring obligations under a Corporate Integrity Agreement can form the basis for False Claims Act (FCA) liability. A Novel …
Top 10 Lessons From The Bradford Regional Case
March 17, 2011 Leave a Comment
If you have not done so already, you should read the court’s opinion in United States ex rel. Singh v. Bradford Regional Medical Center, No. 04-186 (W.D. Pa. Nov. 10, 2010). The case examined an arrangement between Bradford Regional Medical Center (Hospital) and Drs. Vaccaro and Saleh and their practice entity …
Physician Fraud and Abuse Guidelines: Starting Young
November 23, 2010 Leave a Comment
According to an Office of Inspector General (OIG) study, less than half of all U.S. medical schools provide training on Medicare and Medicaid fraud and abuse laws. Further, the OIG study found that only two-thirds of residency and fellowship programs reported providing their residents or fellows with any …
CMS Issues Voluntary Self-Referral Disclosure Protocol
September 23, 2010 Leave a Comment
Today CMS issued its voluntary self-referral disclosure protocol (SRDP) as required under Section 6409 of the Patient Protection and Affordable Care Act (PPACA). Section 6402 of PPACA requires certain providers, suppliers and other entities to report and return overpayments by the later of (i) 60 days after the …