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OIG Exclusion Actions — Mandatory and Permissive Exclusion Authorities

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The most severe administrative sanctions available under the Social Security Act stems from the authority of the Office of the Inspector General (OIG) of the Department of Health and Human Services (HHS) [1] to “exclude” individuals and entities from participating in Federal health care programs. Indeed, an OIG Exclusion [2] imposed by the OIG is […]

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Healthcare Law Representation

Liles Parker attorneys have decades of experience practicing health care law.  Several of our attorneys served as Federal prosecutors and held significant positions at the U.S. Department of Justice.  Our health care transactional and regulatory attorneys have the knowledge and counseling skills necessary to efficiently resolve your health care business issues at the lowest possible

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A UPIC Audit is Serious Business — Is Your Office Prepared?

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(Updated December 2020): Of the many contractors working for the Centers for Medicare and Medicaid Services (CMS), Unified Program Integrity Contractors (UPICs) are by far the serious financial threat to your practice, home health, hospice or DME company. A UPIC audit is serious business. Simply put, the UPIC program was intended to consolidate the work

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Small Business Administration Releases Express Bridge Loan Pilot Program for COVID-19

COVID-19 Updates, Medicare, Medicaid & Private Payor Updates /

(March 26, 2020): The Small Business Administration (“SBA”) announced an Express Bridge Loan Pilot Program on March 25, 2020.[1] The Express Bridge Loans are available to businesses, including health care providers, to provide economic relief for businesses impacted by the Coronavirus Disease (COVID-19) while they await long-term disaster financing.[2] I. Background: The Express Bridge Loan

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COVID-19 SBA Loan Support May be Available for Qualified Health Care Providers

COVID-19 Updates, Medicare, Medicaid & Private Payor Updates /

(March 25, 2020): The Small Business Administration (SBA) offers loans to small businesses through community lenders. The SBA acts as guarantor for these loans. In addition to the traditional lending, the SBA is also authorized to offer disaster assistance to businesses, renters, and homeowners who are located in regions with “declared disasters.”[1] Small businesses impacted

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Overview of Dental Claims Audits and Investigations by Medicaid and Private Payors in 2019

Dental Audits & Compliance /

(March 4, 2020): Many dentists and dental practices around the country are glad that 2019 is behind us.  Last year was a banner year for law enforcement investigators and administrative auditors of dental claims.  Federal and State prosecutors around the country actively pursued both civil and criminal cases against individual dentists for a variety of

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Telemedicine Audits of Evaluations by Referring Physicians are Increasing

Medicare, Medicaid & Private Payor Updates /

(February 17, 2020): Over the last few months, we have seen a significant increase in the number of telemedicine audits and investigations by law enforcement and program integrity contractors.  Unfortunately, most of the calls we have received have been from physicians who have inadvertently become associated with a number of improper telemedicine schemes.  The purpose

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Providers Should Ensure That They Are Fully Aware of All of the Collateral Consequences that May Occur When Settling with the Government

Medicare, Medicaid & Private Payor Updates /

(December 2, 2019): Over the past several years, several clients have come to our Firm who have resolved disputes through such mechanisms as settlement agreements, criminal pleas, or consent orders, either because they specified minimal penalties or because they did not include any time in incarceration. Later they discover that agreeing to these resolutions has

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What is the CMS Preclusion List? What is the Difference Between an Exclusion and a Preclusion Action? How Can You Appeal a CMS Preclusion Action?

Medicare, Medicaid & Private Payor Updates /

(October 8, 2019): On April 16th, 2018, the Department of Health & Human Services (HHS), Centers for Medicare and Medicaid Services (CMS), issued a Final Rule entitled, “Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs, and the PACE Program.”

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DEA Audits / DEA Registration Defense / DEA Enforcement Actions

The Drug Enforcement Administration (DEA) was first established in 1973[1] and is an investigative / enforcement component of the U.S. Department of Justice.  The DEA is the primary federal agency that has been tasked with the enforcement of laws governing the illegal sale, distribution, manufacturing or use of drugs.  The primary statute enforced by the

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