Insights & Analysis
Practical guidance on PBM audits, federal investigations, compounding defense, DEA enforcement, telehealth compliance, and the regulatory pressures facing pharmacies and providers nationwide.
More articles — Page 13
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Physician Supervision in Wound Care Clinics
How incident-to billing rules tie wound care claims to direct or general physician supervision, and why undocumented supervision d…
Government Intervention: What the Decision Signals
What DOJ's decision to intervene or decline under 31 U.S.C. § 3730 signals for a qui tam case's value, and why declination does no…
Implied Certification After Escobar
How the Supreme Court's Escobar decision set the two-part implied certification test and a demanding materiality standard courts s…
Healthcare Fraud Sentencing: How Loss Is Calculated
How federal courts calculate actual versus intended loss under Section 2B1.1, and why the billed-amount presumption is often the k…
UPIC Interview Requests: Should You Agree
A voluntary UPIC interview request is not a subpoena, but an unprepared answer can still shape a later civil or criminal fraud ref…
UPIC-Initiated Medicare Payment Suspensions
How a UPIC suspends Medicare payments on a credible allegation of fraud, the 15-day rebuttal window, and how long a suspension can…
Signature Log Deficiencies: The Most Common Audit Finding
A missing or illegible signature is one of the most common PBM audit findings pharmacies face, and one of the most recoverable wit…
Grand Jury Testimony: Preparing a Provider Witness
How DOJ classifies grand jury witnesses as target, subject, or witness, and what a physician should know before testifying.
Self-Auditing Your Pharmacy Before the PBM Does
How pharmacies can sample their own claims, fix the systemic cause behind errors, and document the fix before a PBM audit finds it…