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.

Enforcement Efforts Targeting Aquatic Therapy Providers and CPT Code 97113 Claims

(October 3, 2022): Aquatic therapy is a common method of rehabilitation and maintenance for several types of injuries and conditions, and the practice is widely accepted by Medicare, Medicaid and many private payors. Historically, both payors and law enforcement have routinely audited aquatic therapy claims. The Centers for Medicare and Medicaid Services (CMS) initially suspended …

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Incident To Billing Practices are Under Law Enforcement’s Microscope. Are Your Incident To Billing Practices Compliant?

(September 20, 2022): In the Medicare billing context, the term “Incident To” refers to the fact that under certain circumstances, the services of non-physician, mid-level practitioners (such as Nurse Practitioners (NPs) and Physician Assistants (PAs)) are “. . . furnished as an integral, although incidental, part of the physician’s personal professional services in the course …

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Balloon Sinuplasty Fraud / Balloon Dilation Fraud Prosecutions are Increasing Around the Country

(May 25, 2022): In recent years, federal regulators have initiated a significant number of audits and investigations examining the improper billing of claims for balloon sinuplasty / balloon dilation procedures by Otolaryngologists (commonly referred to as Ear, Nose and Throat (ENT) physicians. Depending on the specific facts in each case, the improper billing of balloon …

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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 …

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? Read More »

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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