Facebook Google LinkedIn

Fair Market Value and Anti-Kickback Statute considerations for Physician Lease Arrangements

In a recent ruling from the U.S. Court of Appeals Eleventh Circuit, a whistleblower suit was decided in favor of the defendant because the relator failed to prove a lack of fair market value consistent with Federal Civil Rule 9(b) particularity requirements. Bingham v. HCA, Inc. Case No. 1:13-cv-23671 (11 th Cir.2019) was initially filed in 2014. T...
Continue reading

DOJ Cooperation Credit Guidance: What is the Benefit of Cooperation?

The U.S. Department of Justice (DOJ) issued policy guidance on May 6, 2019, about providing credit in False Claims Act (FCA) settlements to corporations for "disclosure, cooperation, and remediation." See https://www.justice.gov/jm/jm-4-4000-commercial-litigation#4-4.112 . While the guidance explains how the DOJ can award cooperation credit to corp...
Continue reading

THE DEPARTMENT OF JUSTICE IN APRIL 2019 UPDATED GUIDANCE FOR EVALUATING CORPORATE COMPLIANCE PROGRAMS. HOW DOES YOUR ORGANIZATION RESPOND TO THE THREE FUNDAMENTAL COMPLIANCE QUESTIONS?

The "Principles of Federal Prosecution of Business Organizations" in the U.S. Department of Justice (DOJ) Justice Manual describe specific factors that prosecutors should consider in conducting an investigation of a corporation, determining whether to bring charges, and negotiating plea or other agreements. Additionally, the United States Sentencin...
Continue reading

2018 All-Time Record Year for HIPAA Enforcement

The Office of Civil Rights recently reminded us of the importance of HIPAA privacy and the cost of neglect. In a February 7, 2019, posting the Office for Civil Rights (OCR) concluded an all-time record year in HIPAA enforcement activity. OCR also recently issued a Report to Congress detailing the frequency of types of breaches. See Report to Congre...
Continue reading

Security Risk Analysis: Ensure Your Risk Analysis includes an assessment of the Health and Human Services Voluntary Cybersecurity Practices for the Health Industry

On Friday, December 28, 2018, the Department of Health and Human Services (HHS) released the "Health Industry Cybersecurity Practices (HICP): Managing Threats and Protecting Patients" publication. The four-volume publication aims to provide voluntary cybersecurity practices to healthcare organizations of all types and sizes. This document is a valu...
Continue reading

Medicare Compliance Journal

Call and schedule your meeting today! Contact

Facebook Google LinkedIn

Upcoming Events

There are currently no upcoming events.

Click here to see past events

Get Directions

Get Directions

Office Location

Buffalo Office

300 International Dr
Williamsville, NY 14221

Phone: +1 (716) 352-0196
Fax: +1 (716) 626-3001
Email: robert@trusiaklaw.com