Author: Scott

OIG Again Proposes Adding Diagnosis to Prescriptions to Stem Medicare Fraud

A couple of months ago, the Principal Deputy Inspector General and its  Chief Medical Officer wrote  a compelling editorial  (https://www.statnews.com/2021/03/01/why-drug-prescriptions-should-include-diagnoses/), advocating why prescriptions should include...

The Irony in a Low Error Rate: Is CMS Doing Enough to Avoid Improper Medicaid Payments?

The integrity of any system, from payroll good manufacturing practices to tax returns, is the documentation to support an ultimate result.  Of course, the same...

The GAO Has 4 Suggestions to Avoid Improper Medicaid Payments Due to Insufficient Documentation

In a United States Government Accountability Office’s (GAO’s) March 2019 report, the GAO noted that the number of reported improper payments due to insufficient documentation...

Highly Dependent Residents and Understaffed Nursing Facilities: A Recipe for Major Medicare Fraud?

The Case of United States v. Kindred Healthcare The U.S. v. Kindred Healthcare is a fascinating case because it presents allegations that Medicare and Medicaid...

GAO Finds that Improper Payments in 2019 Exceed $175 Billion

On March 2, 2020, the GAO delivered its report on fiscal year 2019 to Congress. In this blog post, we delve into more detail about...

Payment Integrity Remains a Fiscal Concern for Federal Agencies

Improper payments – those payments that either should not have been made or were made in an incorrect amount – are still a major area...

What are the Requirements for Issuing and Using Guidance Documents?

In the previous blog post, we covered the recent “Good Guidance Practices” introduced by HHS in August 2020.  The new “Good Guidance Practices,” in our...

What is Considered Appropriate “Guidance” from CMS?

Guidance documents issued by the Centers for Medicare & Medicaid Services (CMS) have come under increased scrutiny in recent years.  The U.S. Supreme Court, in...

False Claims Act and Whistleblower Retaliation – Legal Analysis of United States v. Novartis

In our previous blog post, we began the discussion of the recent Whistleblower Protection case of United States v. Novartis, where the employee (“Relator”) became...

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