Using Artificial Intelligence to Detect Potential Health Care Fraud

How AI Can Mitigate or Create Fraud and Abuse Risks in the Healthcare Industry The age of Artificial Intelligence is clearly upon us.  Unless you are living in a cave it would be impossible not to understand that it will have an enormous impact on nearly every aspect of society, including the hea...

Concierge Medical Practice Definition and Overview

Concierge Medicine Practice Membership Model and Enhanced Access A concierge medical practice typically operate on a membership basis, granting patients access to enhanced services and exclusive benefits in exchange for an annual or monthly fee. This model allows physicians to maintain smaller pa...

Senate Subcommittee (November 2023): Policy Considerations for AI in Health Care

In November 2023, the Subcommittee on Primary Health and Retirement Security under the Senate Committee on Health, Education, Labor and Pensions held a hearing to examine the implications of artificial intelligence (AI) in health care. The hearing brought together lawmakers, technology experts, h...

Compliance Officer Authority and Resource Allocation

The Department of Justice (DOJ) uses resource allocation as a key measure when evaluating the effectiveness of compliance programs. Allocating sufficient resources to the compliance function is foundational to any systematic compliance initiative and remains central as regulatory expectations evo...

Concierge Medicine Impact of Physician Ethical Obligations on Structure

How Ethics Shape the Design and Delivery of Concierge Medicine Concierge Medicine Introduction Concierge medicine has emerged as a popular healthcare model, offering patients enhanced access, personalized care, and a variety of premium services in exchange for membership fees. While this approach...

Coronavirus Checklist for Nursing Homes and Hospitals

Comprehensive Guide to Hospital Readiness and Infection Control Introduction The ongoing threat of coronavirus (COVID-19) requires hospitals to maintain rigorous preparedness and response plans. This detailed checklist is designed to help hospital administrators and healthcare teams ensure readin...

Proposed Revisions to the SAMHSA Regulations

Impact on Communications Between Part 2 and Non-Part 2 Providers Introduction In our ongoing engagement with behavioral health and substance abuse programs, we maintain a vigilant focus on matters relating to patient record confidentiality governed by 42 CFR Part 2, commonly known as the SAMHSA r...

Congress Enacts the Eliminating Kickbacks in Recovery Act of 2018

Congress has enacted a new Anti-Kickback law, known as the Eliminating Kickbacks in Recovery Act of 2018 (EKRA). This legislation specifically targets arrangements involving recovery homes, clinical treatment facilities, and laboratories. Congressional Intent and Purpose The primary intent behind...

Apply the 60-Day Repayment Rule to Medicaid Overpayments

Overview of Overpayment Reporting and Repayment The Affordable Care Act (ACA) imposes specific requirements on individuals and entities that receive overpayments from designated government health programs. Under the ACA, any person who has received an overpayment from programs such as Medicare Pa...

The Incentive to Self Disclose False Claims Act Overpayments

Proactive Compliance and Regulatory Oversight The Department of Justice (DOJ), in collaboration with other regulatory agencies, places a strong emphasis on the proactive monitoring of compliance by businesses. Recognizing that governmental resources alone are insufficient to uncover every instanc...

Deconstructing the “HIPAA Bias.”

Understanding HIPAA and Its Interaction with State and Federal Confidentiality Laws HIPAA, the body of regulations designed to protect the confidentiality of patient health care information, has been highly effective in creating widespread awareness within health care facilities. Most staff membe...

DOJs New Evaluation of Corporate Compliance Programs – The Essence of Compliance

The Criminal Division of the United States Department of Justice (DOJ) revised its Evaluation of Corporate Compliance Programs in April 2019. Initially introduced in 2017, this document provides prosecutors with structured guidance for investigations, charging decisions, and plea negotiations. Th...

Telemedicine IT Donations and the Anti-kickback Statute OIG Opinion 18-03

Overview of the OIG Advisory Opinion No. 18-03 The Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 18-03 regarding an arrangement in which a federally qualified health center look-alike (the “Provider”) proposes to donate informati...