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DOJ Continues to Target Health Care Companies - False Claims Act Settlements and Judgments in Fiscal Year 2021

The Department of Justice recently reported that in fiscal year 2021, it received more than $5.6 billion in settlements and judgments. Of that total, over $5 billion relates to matters that involved the health care industry....more

What to Expect, Part III: Modified AKS Safe Harbor for Personal Services & Management Contracts

The Office of Inspector General’s (“OIG”) new Anti-Kickback Statute (“AKS”) regulations modify the safe harbor for personal services and management contracts (42 CFR § 1001.952(d)) in a manner that allows providers...more

What to Expect, Part II: New Stark Law Definitions for Physician Compensation

The Centers for Medicare & Medicaid Services’ (“CMS”) new final rule amending the implementing regulations of the Physician Self-Referral Law (“Stark Law”), in part, defines fundamental terms, such as “fair market value” and...more

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