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Fifth Circuit Vacates Fraud Conviction after Denying Codefendants’ Appeal

The U.S. Fifth Circuit recently reversed a former home health agency employee’s conviction and vacated his sentence related to three counts of healthcare fraud and abuse. Jonathan Nora was convicted by the trial court of...more

Update: House Passes, President to Sign American Rescue Plan With Senate Healthcare Provisions

On March 10, 2021, the U.S. House of Representatives narrowly passed H.R. 1319, the American Rescue Plan Act of 2021, on a largely partisan basis by a 220-211 vote. Final passage came four days after the U.S. Senate amended...more

U.S. Senate Passes American Rescue Plan – 10 Key Updates for Healthcare Providers

On March 6, 2021, the U.S. Senate narrowly passed H.R. 1319, the American Rescue Plan Act of 2021, by a 50-49 vote, along entirely partisan lines. Sen. Dan Sullivan (R-AK) missed the vote after joining with all Republicans on...more

Per-Click Compensation for Philanthropic Entity’s COVID-19 Vaccine Site Low Risk of Fraud According to OIG

As previously discussed, on April 3, 2020, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a process for inquiries to be submitted to OIG about whether administrative enforcement...more

U.S. House Passes American Rescue Plan – 15 Provisions for Healthcare Providers

In the early morning of Feb. 27, 2021, the U.S. House of Representatives narrowly passed H.R. 1319, the American Rescue Plan Act of 2021, by a 219-212 vote. Two Democrats joined with a united Republican caucus to oppose the...more

First Provider Relief Fund Indictment

The U.S. Department of Justice (DOJ) announced charges this month against a Michigan woman, Amina Abbas, for embezzling government property. This indictment is the first in the nation related to the CARES Act public health...more

CMS statement clarifies agency’s view that the Stark Law final rule is effective

Industry publication BVWire quoted a statement from the Centers for Medicare & Medicaid Services (CMS) that gives healthcare providers more certainty to rely on the much heralded final rule modernizing the physician...more

Fraud and Abuse Rules Part V: Easing Stark Law Compliance

As discussed in a previous McGuireWoods alert, the U.S. Department of Health and Human Services (HHS) published final rules that significantly amend the regulations to the Physician Self-Referral Law (Stark Law), the federal...more

Reimbursement Consultant Could be Liable Under the FCA

The Northern District of Illinois recently denied a hospital reimbursement consultant’s motion for summary judgment, finding that the consultant could be held liable under the FCA based on the theory that the consultant’s...more

“Expert” Analyzing FOIA Report Barred as Public Disclosure

A federal district judge in the Northern District of California dismissed a qui tam suit in late 2020 under the public disclosure bar of the False Claims Act (“FCA”). United States ex rel. Jones v. Sutter Health, No....more

Fraud and Abuse Rules Part III: New Value-Based Arrangement Protections

As discussed in a previous McGuireWoods alert, the Department of Health and Human Services (HHS) published final rules, effective Jan. 19, 2021, that significantly amend the Physician Self-Referral Law (Stark Law), the...more

HHS Delays Provider Relief Fund Reporting — Five Updates for Healthcare Providers

The U.S. Department of Health and Human Services (HHS) announced on Jan. 15, 2021, that it was delaying both (i) the deadline for the initial final report from recipients of the Public Health and Social Services Emergency...more

Omnibus Appropriations Package – 15 Key Provisions for Healthcare Providers

Passed by Congress Dec. 21, 2020, and signed by President Donald Trump Dec. 27, 2020, the $1.4 trillion omnibus Consolidated Appropriations Act, 2021 (H.R. 133), includes numerous statutory provisions that directly affect...more

Fraud and Abuse Rules Part I: Changes to Patient Inducement and Kickback Policies

As discussed in a previous McGuireWoods alert, the U.S. Department of Health and Human Services (HHS) published final rules expected to be effective Jan. 19, 2021, that significantly amend the Physician Self-Referral Law...more

Stark Law and Anti-Kickback Statute Reform: Six Key Insights for Private Equity Healthcare Affiliations

Two new healthcare fraud and abuse final rules, effective Jan. 19, 2021, may increase flexibility for private equity firms exploring opportunities in the healthcare space as well as private equity-backed healthcare platforms...more

Omnibus Appropriations Package Includes Changes for Medicare and Medicaid Beneficiaries

Passed by Congress Dec. 21, 2020, and signed by President Donald Trump Dec. 27, 2020, the $1.4 trillion omnibus Consolidated Appropriations Act includes numerous provisions that directly impact Medicare and Medicaid...more

New Spending Package Includes Provider Relief Fund Reporting Changes and More Funding

On Dec. 27, 2020, President Trump signed the Consolidated Appropriations Act, 2021 (H.R. 133), an appropriations and stimulus package that includes changes to the Public Health and Social Services Emergency Fund (Provider...more

MedMal Plaintiff Uses Anti-Kickback and Stark to Avoid Summary Judgment

A federal court recently allowed a plaintiff’s state law negligence claim, which utilized the Anti-Kickback Statute (“AKS”) and federal physician self-referral law (the “Stark Law”) as legal support to survive a motion for...more

Eleventh Circuit Holds “Knowingly and Willfully” Does Not Require Motive for Kickback Recipient

A recent Eleventh Circuit opinion clarified the mens rea burden the Government must prove to establish criminal intent to violate the Federal Anti-Kickback Statute (“AKS”) for a recipient or payee of a kickback or bribe under...more

Fifth Circuit Upholds Health Care Fraud Convictions for Home Health Agency Employees

The U.S. Fifth Circuit recently upheld convictions and sentences against five named defendants, each charged with conspiracy to commit health care fraud, conspiracy to violate the Federal Anti-Kickback Statute (AKS) and...more

HHS Finalizes Stark Law, AKS Changes to Reduce Burdens on Healthcare Providers

On Nov. 20, 2020, the U.S. Department of Health and Human Services (HHS) published two long-awaited final rules significantly amending the Physician Self-Referral Law (Stark Law), the federal Anti-Kickback Statute (AKS) and...more

California Doctor Pleads Guilty to EKRA Violations

On September 15, 2020, Doctor Akikur R. Mohammad, a California resident and drug treatment facility owner, pled guilty before the U.S. District Court of New Jersey for violating the Eliminating Kickbacks in Recovery Act...more

Health Department Updates Provider Relief Fund Reporting Guidance

The U.S. Department of Health and Human Services (HHS) recently issued updated reporting requirements, a policy update memo and answers to frequently asked questions (FAQs) addressing mandatory final reports from recipients...more

Federal Judge Dismisses False Claims Act Lawsuit Citing Advertisement as Public Disclosure

Recently, a federal judge in the Central District of California granted a Motion to Dismiss on behalf of a manufacturer of ophthalmic lenses alleged to have engaged in an illegal kickback scheme, based on the public...more

CMS Updates Medicare Accelerated and Advance Program Repayment Guidance and Start Date

The Centers for Medicare & Medicaid Services (CMS) recently issued an updated fact sheet and a FAQ page detailing the repayment terms for Medicare Part A providers and Part B suppliers who received payments under its...more

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