In this episode, Monica Chmielewski, vice chair of Foley’s Health Care Practice Group and Shannon Sumner, Chief Compliance Officer and Nashville’s Office Managing Principal of PYA explore how supply chain compliance is...more
On December 11, 2024, the U.S. Department of Health & Human Services’ Office of Inspector General (OIG), issued a Special Fraud Alert (Alert) focusing on financial arrangements involving Medicare Advantage (MA) Organizations...more
5/23/2025
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Fraud ,
Government Agencies ,
Health Care Providers ,
Insurance Industry ,
Medicare ,
Medicare Advantage ,
OIG ,
Regulatory Reform
In this episode, Let’s Talk Compliance Hosts Jana Kolarik a partner of Foley’s Health Care Practice Group and PYA principal Angie Caldwell, discuss physician compensation plans and the latest trends in physician compensation...more
As part of our work with clients and preparing for Let’s Talk Compliance events, we often notice trends through the questions we receive. The following physician compensation compliance topics are currently trending....more
Although most health care lawyers and compliance officers who review and analyze physician compensation understand that fair market value (FMV) is important, the nuances around FMV are sometimes missed....more
8/13/2024
/ Anti-Kickback Statute ,
Audits ,
Chief Compliance Officers ,
Compensation ,
Compliance ,
Corporate Integrity Agreement ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Fair Market Value ,
Healthcare ,
Medical Coding ,
OIG ,
Physician Payments ,
Stark Law ,
Valuation
In connection with the November 2023 Health Care Compliance Association’s (HCCA) Healthcare Enforcement Compliance Conference, and with acknowledgment by the Chief Counsel to the Inspector General, Rob DeConti, of the long...more
11/8/2023
/ Advisory Opinions ,
Anti-Kickback Statute ,
Audits ,
Civil Monetary Penalty ,
Compliance ,
Corporate Integrity Agreement ,
Department of Health and Human Services (HHS) ,
Enforcement ,
Healthcare Fraud ,
OIG ,
Private Equity ,
Risk Assessment ,
Self-Disclosure Requirements
In this episode, partner Jana Kolarik of Foley’s Health Care Practice Group interviews partner Roger Strode of Foley’s Health Care and Transactional Practice Groups and Michael Ramey, managing principal of PYA's Strategic and...more
10/17/2023
/ Acquisitions ,
Anti-Kickback Statute ,
Compliance ,
Due Diligence ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Hospital Mergers ,
Indemnity ,
Private Equity ,
Recapitalization ,
Self-Disclosure Requirements ,
Stark Law
CMS made impactful changes to the Federal physician self-referral law’s (i.e., Stark Law’s) regulations in its Final Rule that were effective January 19, 2021 (with the exception of the changes to 42 C.F.R. § 411.352(i) that...more
1/21/2021
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Commercially Reasonable Efforts ,
Compensation ,
Cybersecurity ,
Final Rules ,
Physicians ,
Remuneration ,
Stark Law ,
Value-Based Care ,
Value-Based Payments
As previously reported in our August 16, 2019 and February 18, 2020 blogs, the Florida Patient Brokering Act (Florida PBA) was amended on July 1, 2019 to change the exception to the Florida PBA from conduct “not prohibited...more
Federal and state legislatures have taken note of the nationwide opioid crisis and recently responded with legislative attempts to—among instituting other legal changes—broaden prohibitions on abusive health care payment...more
Welcome to Foley & Lardner LLP’s Health Care MarketTrends. In this issue, we examine private equity investment in specialty areas of the health care industry, specifically dermatology and orthopedics....more
9/17/2019
/ Anti-Kickback Statute ,
Audits ,
Billing ,
Centers for Medicare & Medicaid Services (CMS) ,
Coding ,
Health Care Providers ,
Hospitals ,
Investors ,
Medicaid ,
Medicare ,
Private Equity ,
Private Equity Firms ,
Specialty Healthcare ,
Stark Law
This is an uncomfortable summer for health care providers in Florida! The legal landscape changed dramatically over the 4th of July holiday. Buried in Florida’s HB 369 regarding substance abuse services was a dramatic...more
As noted in previous Health Care Law Today blog posts, we have seen an uptick in private equity recapitalization transactions in orthopedics. We expect this trend to continue, and to pick up pace, as the economy remains...more
1/8/2019
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Homeland Security (DHS) ,
Health Care Providers ,
Hospitals ,
Joint Venture ,
Physicians ,
Private Equity ,
Private Equity Funds ,
Recapitalization ,
Stark Law
Just in time for the New Year, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued final regulations (Final Regulations) that revised two existing Anti-Kickback Statute safe...more
1/19/2017
/ Advertising ,
Ambulance Providers ,
Anti-Kickback Statute ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Discounts ,
FQHC ,
Free Health-Related Services ,
Health Care Providers ,
Medicare Advantage ,
Medicare Coverage Gap Discount Program ,
OIG ,
Pharmacies ,
Safe Harbors ,
Waivers