JD Supra July 28, 2022
The recently-released Health Care Fraud and Abuse Control Program FY 2021 report contains a treasure trove of information for healthcare compliance teams. To gain a better understanding of lessons to be learned from this document we sat down with SCCE & HCCA board member Gabe Imperato, Partner at Nelson Mullins.
The report makes clear, he explained, how much coordination and review there is now among the Office of Inspector General at HHS, the US Department of Justice and also CMS. As a result, a subpoena, or even an inquiry needs to be taken very seriously. Compliance teams need to treat these external actions as if they are a report of non-compliant activity.
The report also reveals that there has been...
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