On February 12, 2016, the Department of Health and Human Services, Centers for Medicare and Medicaid Services (“CMS”) promulgated the final rule on the requirement that providers and suppliers receiving funds under the Medicare program report and return overpayments by the later of sixty (60) days after the date on which the overpayment was identified
United States Supreme Court to Address the Theory of “Implied Certification” Under the False Claims Act
On December 4, 2015, the United States Supreme Court granted a Petition for a Writ of Certiorari in Universal Health Services, Inc. v. United States and Commonwealth of Massachusetts ex rel. Julio Escobar and Carmen Correa. The Petition was filed by Universal Health Services, Inc. (“UHS”) challenging the United States Court of Appeals for the
OIG Would Not Sanction Arrangement Involving Payment to Excluded Provider for Pre-Exclusion Services
The latest OIG Advisory Opinion, issued February 9, 2015, addresses the issue of sharing federal health care program payments with an excluded practitioner. While federal statutes prohibit payment by any federal health care program, including Medicare or Medicaid, for items or services furnished by an excluded person or furnished at the medical direction or on