Robert Liles

Robert W. Liles is Managing Partner at the law firm of Liles Parker in Washington, DC. Prior to entering practice, Mr. Liles was an Assistant U.S. Attorney in the Southern District of Texas. Mr. Liles' background is in health care administration. Prior to becoming a lawyer, Mr. Liles worked in various management positions in hospitals in San Antonio and Houston, Texas.

VA Acupuncture Audits of Non-VA, Community Providers are Increasing

(May 20, 2022): Acupuncture audits and investigations by federal, state and private payors have greatly expanded in recent years. One of the most active players conducting acupuncture audits today is the U.S. Department of Veterans Affairs. (VA). It is worth noting that long before traditional Medicare even considered covering acupuncture services,[1] the VA made these …

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State and Federal Hospice Audit and Investigation Efforts are Expanding in 2022

(May 12, 2022): Hospice agencies are again the focus of both state and federal investigators and prosecutors around the country. The number of hospice audits and investigations at both the state and federal levels have risen in 2022. This isn’t surprising given the ever-expanding level of beneficiary participation and cost of Medicare’s hospice benefit program. …

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Will Xiulu Ruan v. United States Finally Bring Some Sanity to Interpretations of the Controlled Substances Act?

(May 2, 2022): The Supreme Court last addressed violations of 21 U.S.C. §841 by a medical practitioner in 1975.[1] Since that time, several circuit courts have taken different approaches when construing the scienter requirements to prove a Controlled Substance Act violation, and how a jury may be instructed when deciding a case.  Hopefully, clarification of …

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The Criminalization of Pain – In 2022, DOJ is Aggressively Investigating and Prosecuting MDs, NPs and PAs for Violations of the Controlled Substances Act

(April 19, 2022): Despite our government’s best efforts, opioid overdose deaths in America are continuing to spiral out of control. According to the U.S. Centers for Disease Control and Prevention (CDC), during the period April 2020 through April 2021, the number of overdose deaths were more than 30% higher than the previous year. While many …

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The OIG Exclusion List of Individuals and Entities is Growing. What Steps are You Taking to Avoid Hiring or Contracting with an Excluded Individual or Entity?

(March 17, 2022): Over the last few months (from mid-November 2021 through mid-March 2022), the number of excluded individuals and entities on the Department of Health and Human Services, Office of Inspector General’s (OIG’s) List of Excluded Individuals/Entities (LEIE) has grown by approximately 15%. According to our friends at Exclusion Screening,[1] this rapid expansion of …

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A Review of Dental Enforcement in 2021 and a Look at What Dentists Should Expect in 2022

(February 22, 2022): The treatment and business challenges presented by COVID-19 over the last two years have been especially demanding on dentists and their practices. Between the lockdowns and a hesitancy by many individuals to schedule non-emergent dental care, many dental practices have found it tougher than ever to maintain previous levels of profitability. Not …

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The Collateral Enforcement Risks of DOJ Civil Investigative Demands (CIDs) Issued in False Claims Act Matters and Cases

(October 21, 2021): The False Claims Act [1] remains the primary civil enforcement tool utilized by the U.S. Department of Justice (DOJ). While the results of Fiscal Year (FY) 2021 have not yet been published, settlements and judgements in FY 2020 exceeded $2.2 billion. Of this total, $1.8 billion were related to the health care …

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What is a Referral Under the Anti-Kickback Statute?

(January 26,  2021): Under the Anti-Kickback Statute (Anti-Kickback Statute), what constitutes a referral? Notably, neither the term referral nor the term referring (as it is referred to in the law) are defined in the statute. While you may be tempted to argue that a referral only occurs when one party refers a beneficiary to another party …

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Prepayment Reviews and Audits of Medicare Claims are Ongoing. Are Your Claims Being Audited?

(January 19, 2021):  As you will recall, on March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) suspended most Medicare audits and reviews due to the COVID-19 national emergency.  In early August, CMS instructed its contractors to resume their prepayment and postpayment audit activities. Over the last six months, we have seen a …

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Chiropractor Owned Multidisciplinary Practices are at a Higher Risk of Audit

(January 13, 2021):  Over the last few years, we have noted a significant increase in the number of audits initiated against Chiropractor owned multidisciplinary practices.  Typically, these integrated medical practices and clinics employ at least one Chiropractor (typically in an ownership or managerial capacity), along with multiple Doctors of Medicine (MDs), Doctors of Osteopathy (DOs). …

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