Changes to the Medicare Recovery Audit Program

June 29, 2015
AMARILLO, TX – The Recovery Audit Contractors, or RACs, are Medicare’s bounty hunters. These auditors are paid a contingency fee to identify improperly paid claims. While RACs are paid a contingency fee to identify over and underpayments, sup

OIG Fraud Alert – Physician Compensation Arrangements

June 22, 2015
AMARILLO, TX – There are two important principles that a DME supplier must adhere to. The first is that the DME supplier “lives in a glass house.” If the DME supplier is doing something it should not be doing, then “someone knows about it

OIG Self-Dislosure Protocol – Part 3

May 4, 2015
AMARILLO, TX – Today’s DME supplier is highly regulated. It must abide by a plethora of federal anti-fraud laws, including (but not limited to) the Medicare anti-kickback statute and the federal False Claims Act. Because the day-to-day operat

Legal Issues Related to Supplier Price Discounts

April 6, 2015
AMARILLO, TX – 42 U.S.C. §1320a-7(b)(6)(A) states, in relevant part: The secretary may exclude the following individuals and entities from participation in any Federal health care program (as defined in section 1320a–7b (f) of this title

Real World Case – The Epilogue

March 30, 2015
AMARILLO, TX – In September, I wrote an article entitled, Medicare Anti-Kickback Statute – Real World’ Case. In the article, I discussed a front page Wall Street Journal (WSJ) story entitled, “A Fast-Growing Medical Lab Tests Anti-Kickbac

Billing Part B Patients in SNF Certified Facilities

March 23, 2015
AMARILLO, TX – The government has taken the position that if a facility originally received Medicare certification for participation as a SNF, then that singular event prohibits a DME supplier from billing Part B for products delivered to custo