Compensating Marketing Reps of Affiliated Companies

June 25, 2022

AMARILLO, TX - One of the safe harbors is the “Employee Safe Harbor.” It states that if a person is a bona fide employee (full-time or part-time) of a provider/supplier, the compensation paid to the employee does not violate the AKS.

Negotiating Managed Care Contracts

June 10, 2022

AMARILLO, TX - Historically, DME suppliers have taken care of Medicare patients and have billed CMS directly. This is known as “Medicare fee-for-service” (Medicare FFS). Also, historically, suppliers have taken care of state Medicaid patients.

Personal Services and Management Contracts Safe Harbor: OIG Guidance

June 6, 2022

AMARILLO, TX - All health care providers, including DME suppliers, should be aware of the federal anti-kickback statute (“AKS”).

Federal Laws: A Primer

May 27, 2022
AMARILLO, TX – DME suppliers live in the proverbial “glass house.” If a supplier is doing something it should not be doing, someone knows about it. That “someone” can be an existing employee, an ex-employee, a government enforcement/reg

Exceptions to the Beneficiary Inducement Statute

April 22, 2022
AMARILLO, TX – Section 1128A(a)(5) of the Social Security Act (the “Beneficiary Inducement Statute”) prohibits a person from offering or transferring to a Medicare or Medicaid beneficiary any remuneration that the person knows or should kno

AOBs: Blue Ink or Electronic?

April 14, 2022
AMARILLO, TX – A common question is whether a DME supplier is limited to collecting blue ink AOBs…or if the supplier can rely on recorded phone calls for AOBs. The short answer is that the supplier can use recorded phone calls for AOBs, but