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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Mandatory Versus Permissive OIG Exclusion: What Triggers Each
Mandatory OIG exclusion follows automatically from certain convictions; permissive exclusion is OIG's discretionary call under a s…
Wound Care Provider Compensation Arrangements: Product Use and Productivity Incentives
Wound care bonuses tied to product use or referral volume can trigger Anti-Kickback Statute and Stark Law exposure, not ordinary p…
Telehealth and Pharmacy Referral Arrangements: Steering Risks
How routing prescriptions to one pharmacy exposes telehealth companies to Anti-Kickback Statute risk, and what OIG guidance says a…
Responding to an OIG Subpoena in a Wound Care Investigation
What an OIG subpoena requires, why skin substitute billing is under federal review, and how wound care practices preserve document…
Reporting Practice Locations for Providers Who Deliver Telehealth From Home
CMS permanently lets telehealth providers with an office skip the home address. Here is when it must appear on enrollment, and why…
Credentialing and Hospital Privileges After Board Discipline: Answering the Questions
Hospital, payer, and Medicare applications ask about prior board discipline, and NPDB queries verify the answer, with exposure for…
California Board of Pharmacy Investigations, Citations and Fines
The California Board of Pharmacy investigates complaints, issues citations and fines, and refers serious violations to a formal ac…
Reading an FCA Settlement Agreement: Covered Conduct and Releases
A guide to how DOJ False Claims Act settlement agreements define Covered Conduct, scope the release, and reserve claims that survi…
OIG Exclusion Release in FCA Settlements
OIG decides, separately from the DOJ settlement, whether to exclude a provider, demand a corporate integrity agreement, or release…