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 36
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Responding to a PBM Audit When Records Are Missing
A system migration, a fire, or a ransomware event does not excuse a PBM audit response. What to document, reconstruct, and disclos…

Responding to a DEA Administrative Subpoena
A DEA administrative subpoena under 21 U.S.C. Section 876 can reach dispensing records without a warrant. How to scope, log, and p…

Medicaid Prepayment Review and Documentation Requirements
Medicaid prepayment review holds each claim for documentation before payment. A payment suspension freezes all claims at once, and…

Overlapping Contractor Reviews: UPIC, MAC, and RAC at the Same Time
CMS requires Medicare review contractors to coordinate overlapping UPIC, MAC, and RAC reviews of the same claims, but a provider s…

Reapplying for DEA Registration After Revocation or Surrender
After a DEA revocation or surrender, there is no reinstatement track. Reapplying means a new application judged on the same public…

Reinstatement After an OIG Exclusion
OIG reinstatement takes a written request and OIG's written approval, not just a finished exclusion period. The 90-day filing wind…

Payment Holds During a PBM Audit
When a PBM holds payment or routes claims to manual review during an audit, the provider agreement, not a government rule, control…

When a Telehealth Audit Signals a Criminal Investigation
A Medicare telehealth audit can escalate into a federal criminal referral inside the same file. Here are the signals that mark the…

Indicted in a Healthcare Fraud Case: Arraignment and Release Conditions
What happens after a federal healthcare fraud indictment: self-surrender, arraignment, and Bail Reform Act release conditions, and…
