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Tag: Jill Vogel

Smart Talk

Legal: Comply with safe harbors

August 25, 2015Jill Vogel

A. During a recent Medicare conference, representatives of the Office of Inspector General announced that the healthcare industry should expect to see an uptick in the investigations of alleged Medicare fraud and abuse. True to their word, the OIG has been busy. As the new fiscal year approaches, now is a good time to review your agreements to confirm that they do not violate the federal anti-kickback statute (AKS) or applicable state laws. Generally, the federal AKS prohibits suppliers and providers...

Anti-Kickback Statute, Jill Vogel

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Legal: Maintain culture of compliance

July 27, 2015Jill Vogel

A. Providers can decrease the risk of False Claims Act liability by building and maintaining a culture of compliance in all aspects of their business. For example, suppliers should keep abreast of changes in federal health care program (e.g., Medicare) regulations and ensure that their employees and contractors receive current and refresher training on relevant requirements.Providers should also have (and enforce) compliance policies and procedures that are in harmony with laws, regulations and supplier...

Compliance, Jill Vogel

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Legal: Keep specter of FCA present

May 26, 2015Jill Vogel

A. Part one of this two-part article discusses the False Claims Act (FCA) and its whistleblower (or “qui tam”) provision. Part Two discusses how suppliers can decrease their risk of FCA liability.The FCA creates liability for any person who knowingly submits a false claim to the government or causes another to submit a false claim, or knowingly makes a false record or statement to get a false claim paid by the government. The “reverse FCA” section of the law creates liability...

Jill Vogel, whistleblowers

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