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.

A CMS ZPIC Contract is Quite Lucrative

(September 26, 2012): From the start, Zone Program Integrity Contractors (ZPICs) have worked to separate themselves from their proverbial “bounty hunter” peers – Recovery Audit Contractors (RACs). As you may know, ZPICs are paid on a contractual basis by the Centers for Medicare & Medicaid Services (CMS), instead of by how much money they return […]

A CMS ZPIC Contract is Quite Lucrative Read More »

FCA Express Certification Liability Theory

(September 24, 2012): There are 3 recognized legal theories under which False Claims Act (FCA) liability may be established – the FCA Express Certification, Implied Certification, and Worthless Services theories. As you may know, the FCA is the government’s primary fraud fighting tool, and prohibits the presentation of false claims for payment by the government.

FCA Express Certification Liability Theory Read More »

HHS-OIG Finds ZPICs May Have Conflicts of Interest

(September 13, 2012): Many physicians and other health care providers around the country are reeling from post-payment and pre-payment assessments conducted by Zone Program Integrity Contractors (ZPICs). As ZPIC audits are being conducted, an issue has recently arisen regarding their independence. According to a recent report issued by the Office of Inspector General (OIG), the

HHS-OIG Finds ZPICs May Have Conflicts of Interest Read More »

Texas Medical Privacy Act Takes Effect

(September 11, 2012): They say that “Everything is Bigger in Texas,” and its law concerning medical privacy is no exception. The Texas Legislature recently enacted the Texas Medical Privacy Act (TMPA)[1], also known as the Texas HIPAA law. The new law substantially increases the compliance burden on medical and service providers, suppliers, business associates, third

Texas Medical Privacy Act Takes Effect Read More »

What Should I Do If I Discover A Breach of PHI?

(September 6, 2012): What should you do if you discover a breach of PHI (Protected Health Information). The short answer is: it all depends on who you are. With the rise in concern over and enforcement of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), patients, families, practitioners, and health care executives need

What Should I Do If I Discover A Breach of PHI? Read More »

Options for Responding if Your Practice is Placed on ZPIC Prepayment Review

(September 3, 2012): Zone Program Integrity Contractors (ZPICs) have turned much of their attention to prepayment review, the process by which the Medicare contractor reviews a claim for problems before it is paid. Unlike postpayment review, ZPIC prepayment review does not have an administrative appeals process, making these types of reviews incredibly damaging for a

Options for Responding if Your Practice is Placed on ZPIC Prepayment Review Read More »

Overseas Outsourced Billing and Coding – Compliance Risks

(August 16, 2012): Thinking of sending your medical coding and billing functions out of the country? You better think twice. While overseas outsourced billing is growing in popularity for medical office functions, this practice represents a unique and growing set of problems for both physician practices and 3rd party billers. And the news is just

Overseas Outsourced Billing and Coding – Compliance Risks Read More »

Medicare Administrative Appeals Process – An Overview for New Providers

(August 15, 2012): Is this your first time being audited by a Medicare Administrative Contractor (MAC) or a Zone Program Integrity Contractor (ZPIC)? If so, the brief outline below can provide a handy summary of the Medicare appeals process. I. Step 1 – Request for Information: In most instances, a health care provider will receive

Medicare Administrative Appeals Process – An Overview for New Providers Read More »

Healthcare Cloud Computing – Compliance Risks

(August 14, 2012): Cloud computing is in the process of revolutionizing the way that individuals and businesses store, receive, and use their data. You may have heard about it through companies such as Google, Apple, and Microsoft, all advertising sophisticated cloud computing services. But what are the risks your organization faces with respect to healthcare

Healthcare Cloud Computing – Compliance Risks Read More »