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The OPM Debarment Action on Health care Providers - Liles Parker - Dec 2023

The OPM Debarment Process – Responding to an FEHBP Debarment or Suspension Action in 2024

Author: Ashley Morgan, Christin Thompson (December 20, 2023): Most health care providers and suppliers are familiar with the fact that as a participating provider in the Medicare and / or Medicaid programs, certain criminal convictions, adverse licensure actions, and various types of prohibited conduct may subject the provider to exclusion from participation in Federal health […]

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AI in medical billing- Liles Parker - October 2023

AI in Medical Billing: A Benefit or a Compliance Risk?

Author: Christin Thompson, Annabella Denzel (October 10, 2023): In terms of revenues and expenses, health care providers and suppliers have repeatedly faced two unfortunate realities: (1) Reimbursement rates are shrinking, and (2) they are constantly being saddled with additional unfunded mandates (for example, HIPAA compliance, OSHA requirements, compliance obligations, etc. Coupled with ordinary practice expenses,

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laws regulation changes affect billing agreement - Liles Parker

Ever-Changing Federal and State Laws and Regulations are Transforming Third-Party Billing Contracts

(July 28, 2022): The business side of medicine has changed considerably over the last decade. Health care laws, regulations, and administrative policies are constantly evolving. A number of these changes have impacted health care practices, billing companies, and the third-party billing contracts executed between these parties. From its earliest beginnings, the majority of third-party billing

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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 »

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US Supreme Court Lifts Injunctions of CMS Vaccine Mandate

(January 24, 2022): In a 5-4 decision, the US Supreme Court issued a ruling on January 13, 2022 staying the injunctions preventing the implementation of CMS’ Vaccine Mandate in 24 states.[1] As a result, Medicare and Medicaid providers[2] subject to the CMS Vaccine Mandate interim final rule in those states must quickly take steps to

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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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PPP Fraud Cases are Rising. Is Your Company at Risk?

(May 18, 2021): In the last year, to address the devastating economic impact of Covid-19, Congress has passed three massive economic relief packages allocating a total of $2 trillion dollars in aid through the legislation. That’s trillion with a “t.” Within those legislative packages have been funds earmarked for the Paycheck Protection Program to provide

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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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Pierce the Corporate Veil — Are You Personally Liable for a UPIC Overpayment?

(Updated January 9, 2021): Owners of healthcare companies often wonder whether the government can pierce the corporate veil and try to hold the owners personally liable for overpayment claims when facing a program integrity audit by a Unified Program Integrity Contractor (UPIC). [1] This rarely happens, but assuming that a provider does not prevail in

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AbilityOne OIG Audits are Ramping-Up! Is Your Nonprofit Agency Ready for an Audit?

(November 11, 2020):  If you run a nonprofit company that contracts with the federal government through the AbilityOne Program, then you should be aware that inadequate compliance policies could put your nonprofit in danger of facing allegations of waste, fraud, abuse, and mismanagement, onerous audits and investigations, and even civil liability.   Under the AbilityOne Program,

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