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HHS-OIG Flags Certain Extreme Outlier Telehealth Providers as Potentially Engaging in Fraudulent Billing During the Pandemic

USA - September 15 2022 HHS-OIG recently issued a report assessing Medicare program integrity risks arising from telehealth services furnished during the first year of the…

Brenna E. Jenny, Francesca R. Ozinal

Provider Escapes, Contractor Remains in Qui Tam Alleging Noncompliance With Bad Debt Regs

USA - August 26 2022 Recently, the Seventh Circuit partially reversed a district court’s dismissal of a qui tam complaint alleging that debt collection agencies and their…

Brenna E. Jenny, Francesca R. Ozinal

Fourth Circuit Underscores the Risk of Commission-Based Compensation Agreements with Independent Contractors

USA - August 2 2022 In a recent decision, the Fourth Circuit Court of Appeals for the second time in two years held that commission-based compensation arrangements with…

Ahsin Azim, Brenna E. Jenny

Court Rejects “Tenuous” Connection Between FDCA Regulatory Violations and Claims for Payment

USA - July 29 2022 Recently, a district court in the Southern District of Florida dismissed with prejudice a qui tam complaint premised on the alleged sale of products…

Brenna E. Jenny, Dr. Krystalyn K. Weaver

U.S. DOJ and HHS-OIG Scrutiny of Telehealth Services and Arrangements at an All-Time High

USA - July 25 2022 Last week, the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG), took the significant step of issuing a Special…

Meenakshi Datta, Brenna E. Jenny, Donielle McCutcheon, Francesca R. Ozinal