News & Analysis as of

Hospitals Overpayment Physicians

Holland & Hart LLP

Correcting Stark Violations: 90-Day Grace Period

Holland & Hart LLP on

Physicians and entities to which physicians refer may violate the Ethics in Patient Referrals Act (“Stark”) by mistakenly overpaying or underpaying amounts due under a compensation arrangement. For example, a hospital may...more

Health Care Compliance Association (HCCA)

New Hampshire Health System Pays $2.1M in CMP Settlement Over Diagnostic Test Orders

Report on Medicare Compliance 31, no. 35 (September 26, 2022) - For the third time in about 2 1/2 years, hospitals or other providers that are part of Dartmouth-Hitchcock Health, a large health system in New Hampshire,...more

Health Care Compliance Association (HCCA)

Hospital Settles FCA Case Filed by CO Over Modifiers; Make Sure People ‘Feel Heard’

Report on Medicare Compliance 30, no. 32 (September 13, 2021) - John Peter Smith (JPS) Hospital in Fort Worth, Texas, agreed to pay $3.3 million to settle false claims allegations in a case with a hot risk area, a...more

Health Care Compliance Association (HCCA)

Credible Information Is Heart of 60-Day Rule; OIG: Self-Disclosure Pauses the Clock

Report on Medicare Compliance 30, no. 28 (August 2, 2021) - When a hospital realized it had been billing for annual wellness visits without documentation of opioid and substance use screening, it wasn’t a heavy lift to...more

McDermott Will & Schulte

[Webinar] 340B… Or Not 340B: Oversight, Compliance and Enforcement - July 15th, 9:00 am - 10:00 am PT

The 340B Program has gained national attention over the last decade, in part due to the opportunities it provides to generate revenue for participating entities without risk of significant enforcement penalties for...more

Health Care Compliance Association (HCCA)

Radiation Therapy Provider Pays $3.6M in CMP Settlement; OIG: 25 CPT Codes ‘Involved’

Report on Medicare Compliance 30, no. 22 (June 14, 2021) - A Colorado radiation therapy provider has agreed to pay $3.569 million in a civil monetary penalty settlement with the HHS Office of Inspector General (OIG). ...more

King & Spalding

OIG Hospital Compliance Program Audit Claims $22 Million in Extrapolated Overpayments

King & Spalding on

A recent report issued by OIG finding an Indiana community hospital owed over $22 million in extrapolated overpayments carries some important lessons for hospitals audited under OIG’s hospital compliance program. As described...more

Ballard Spahr LLP

The 60 Day Rule — Identification and Knowing Avoidance

Ballard Spahr LLP on

On August 3, 2015, the United States District Court for the Southern District of New York issued an opinion and order in Kane v. Healthfirst, Inc., et al.[1] that provides the first judicial interpretation of the requirement...more

Saul Ewing Arnstein & Lehr LLP

Government demonstrates willingness to enforce Affordable Care Act provision that could cost providers millions of dollars

Under a little-known provision of the Patient Protection and Affordable Care Act (“ACA”), healthcare providers could face millions of dollars in liability for failing to reimburse the government for overpayments in a timely...more

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