Insights & Analysis
Practical guidance on PBM audits, federal investigations, compounding defense, DEA enforcement, telehealth compliance, and the regulatory pressures facing pharmacies and providers nationwide.
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CGS Administrators Medicare Audits: Part B and DME MAC Review
CGS Administrators runs Part B physician review and DME MAC review under separate rules. What a CGS records request actually means…
Minnesota DHS Surveillance and Integrity Review Audits
Minnesota DHS renamed SIRS to MPAI, but the audit authority is the same: payments can be withheld on a credible fraud allegation,…
Reading a CVS Caremark Network Termination Notice
A CVS Caremark network termination notice states its own grounds, for-cause or without-cause status, and effective date. Here is h…
FDA Warning Letters to Telehealth Companies Selling Compounded Drugs
FDA warning letters now name the telehealth company, not just the pharmacy, over false or misleading claims about compounded semag…
But-For Causation in Kickback-Based FCA Claims
Federal circuits are split on whether a kickback must cause a claim, or merely touch one, before it becomes False Claims Act liabi…
RPM Device Malfunction and Data Gap Documentation
Device malfunctions and transmission gaps can push RPM billing below the 16-day threshold for CPT 99454. Here is how to document t…
EHR Audit Logs in Criminal Healthcare Investigations
An EHR's audit trail records who touched a chart, when, and what they did, the same system data investigators and defense counsel…
Pharmacist-Prescribed Claims in PBM Audits: Naloxone, Test-and-Treat and Contraception
Naloxone, test-and-treat and contraception claims bill under a pharmacist's own prescribing authority, and PBM audits are flagging…
MFCU Search Warrants and Records Seizures
When MFCU investigators execute a search warrant at a healthcare practice, Fourth Amendment limits, privilege protections, and cou…