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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Prescribing Controlled Substances to Family Members and Yourself
Federal and state rules on self-prescribing and treating family members with controlled substances, and how violations surface in…
Personal Exposure for Owners and Ordering Physicians in a UPIC Audit
A UPIC overpayment finding against the billing entity can still reach the practice owner, a buyer, or the ordering physician's own…
RPM Interactive Communication in Facility Settings: What Counts
What qualifies as the interactive communication CPT 99457 and 99458 require in a nursing facility, who may provide it, and what do…
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…