Insights & Analysis
Practical guidance on PBM audits, federal investigations, compounding defense, DEA enforcement, telehealth compliance, and the regulatory pressures facing pharmacies and providers nationwide.
The FCA Knowledge Standard After SuperValu
The Supreme Court's SuperValu decision ties False Claims Act scienter to what a defendant subjectively knew, not a reasonable reading invented later.
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OIG Self-Disclosure Protocol: What a Submission Requires
What a complete OIG Self-Disclosure Protocol submission must contain, how damages are calculated, and what resolution brings once…
Moving to Dismiss an FCA Complaint Under Rule 9(b)
Why the first contested motion in a healthcare qui tam case turns on Rule 9(b) particularity, the circuit split, and what leave to…
Skin Substitute Application Coding: CPT 15271 Through 15278
CPT 15271 through 15278 split by anatomic site and measured wound area. A reviewer's first move is checking that split against the…
Hospital Outpatient Wound Center Billing: Facility and Physician Claims
One wound center visit produces two Medicare claims from the same chart, under different rules for documentation, supervision, and…
Establishing the Provider-Patient Relationship by Telehealth
A telehealth prescription built on an intake questionnaire alone is the fact pattern that draws board scrutiny and, in serious cas…
Pharmacy Permit Suspension and Revocation
State pharmacy boards can suspend or revoke a store's permit over grounds, notice and hearing rights, and the path back to dispens…
Patient Records When a Telehealth Platform Shuts Down
When a telehealth platform closes, sells, or freezes accounts, HIPAA retention and access duties stay with the treating clinician,…
License Probation Terms and Early Termination
A probationary license carries practice restrictions, chart review requirements, reporting duties, and a path to petition for earl…
FCA Liability for Billing Companies and Management Entities
The False Claims Act reaches billing companies that cause a false claim, and an indemnification clause does not decide who the gov…