Print PDF Reimbursement Counseling/Fraud and Abuse Compliance

We advise clients on issues related to federal and state reimbursement systems, coding and billing issues, Medicare and Medicaid reimbursement, rate setting, and compliance. We are experienced in representing clients before state Medicaid agencies, Medicare intermediaries and carriers, the Centers for Medicare and Medicaid Services, the Office of the Inspector General, and the United States Attorney’s Office.

Our experience helps us plan and structure transactions to minimize fraud and abuse implications, while at the same time achieving our health care clients’ desired business goals.  We regularly evaluate transactions and analyze their compliance with the Medicare and Medicaid fraud and abuse statutes, the Anti-Kickback safe harbor regulations, and the Stark Physician Self-Referral Laws and applicable exceptions.  Our expertise in this area complements our role as transactional counsel to clients on hospital/physician joint ventures, including the operation of diagnostic imaging facilities, equipment lease arrangements, physician practice acquisitions, and physician recruitment programs.  We know the ins and outs of health care deals, and we steer our clients away from the pitfalls that trap the unwary.

We also assist clients with governmental investigations and provide ongoing consultation regarding compliance with corporate integrity agreements. Through on-site reviews and evaluations of contracts and business relationships between hospitals and physicians referral sources, we identify and analyze potential fraud and abuse concerns.  We then assist our clients in developing compliance programs and policies to educate staff (physician and non-physician), to prevent illegal activity by uninformed employees, to recognize and address compliance issues as they arise, and to minimize client exposure to prosecutions and penalties.