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In Brief: A Digest of Healthcare Audit Defense Projects

Client Success
  • Performed and supervised numerous professional services, including regulatory reviews, compliance with FCPA requirements, adverse private or government audits, civil and criminal investigations, administrative or criminal prosecutions and established and reviewed integrity and compliance programs both nationally and internationally.
  • Developed compliance plans and represented clients in fraud and abuse audits, meaningful use audits, HIPAA privacy and security compliance audits.
  • Prepared fraud and abuse compliance plans, and represented healthcare providers in fraud and abuse complaints, including Medicare and Medicaid complaints.
  • Successfully represented specialty pharmacy in administrative hearings involving adverse audit findings of Medicare and Medicaid billing matters.
  • Conducted an internal investigation for a multihospital health system, made a self-disclosure and negotiated settlement with federal regulators, including defending the system in litigation brought by a physician.
  • Evaluated allegations against healthcare providers from whistleblowers and referrals from Recovery Audit Contractor (RAC) audits.
  • Directed comprehensive audit and regulatory analysis of physician contracts at a children’s hospital and submitted a Stark Law disclosure to CMS under the self-referral disclosure protocol. Provided operational and corrective action recommendations related to audit findings.
  • Assisted with settlement of a Stark Law violation with the Department of Justice and the OIG for the Department of Health and Human Services after a four-year internal investigation, self-disclosure and extensive negotiations. The matter was resolved with no criminal charges, no admissions of False Claims Act violations, and no imposition of a corporate integrity agreement or government oversight.