HHS-OIG recommends providers check exclusion list monthly *

USA - May 10 2013
On May 8, 2013, the US Department of Health and Human Services, Office of Inspector General ("OIG") issued a "Special Advisory Bulletin on the Effect…

Co-authors: Christopher G. Janney, D. McCarty (Mac) Thornton.

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HHS OIG issues updated provider self-disclosure protocol *

USA - April 19 2013
On April 17, 2013, the US Department of Health and Human Services, Office of Inspector General (HHS-OIG) released an updated provider self-disclosure…

Co-authors: Christopher G. Janney, Ramy Fayed.

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Congress extends overpayment recovery period *

USA - January 3 2013
Among the many provisions buried in this week's 150+ page American Taxpayer Relief Act ("ATRA"), one - Section 638 -; amends Section 1870 of…

Co-authors: Holley Thames Lutz , Christopher G. Janney, Ramy Fayed.

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U.S. v. Caronia: a rift in prosecution of off-label promotion? *

USA - December 12 2012
A recent decision by the Second Circuit Court of Appeals is being hailed as a potential "game-changing" defeat for federal prosecutors in their pursuit of criminal indictments and civil False Claims Act cases predicated upon the "off-label" promotion and marketing of FDA-approved pharmaceutical drugs and medical devices.

Co-authors: Jeffrey A. Baumel, Peg Donahue Hall, Sean C. Cenawood, John L. Cleary II.

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2012-02-15 CMS issues proposed overpayment rule *

USA - February 15 2012
On February 14, 2012, the Centers for Medicare & Medicaid Services released its proposed rule to implement § 6402(a) of the Affordable Care Act, which created a new § 1128J(d) of the Social Security Act (entitled, “Reporting and Returning of Overpayments”). 

Co-authors: Holley Thames Lutz , Christopher G. Janney, Ramy Fayed.

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