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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PBM Audit Timeline: From Notice to Final Determination
Every stage of a PBM audit runs on a deadline, from the on-site notice period to the appeal window after a final determination. He…
UPIC Audits of DME Suppliers
UPIC audits of DME suppliers turn on the order chain: standard written orders, proof of delivery, and the CMS supplier standards u…
Conservative Care Requirements Before Advanced Therapy
Medicare will not cover a skin substitute graft or hyperbaric oxygen therapy without proof that conservative wound care failed fir…
Cooperation Credit in Federal Healthcare Settlements
DOJ's cooperation credit policy rewards early, complete disclosure in False Claims Act matters, but the same disclosure can expose…
Civil Investigative Demands: Negotiating Scope
A civil investigative demand can combine document production, interrogatories, and testimony under one order. Scope is negotiable…
Remote Patient Monitoring Medicare Audits
CMS device-day thresholds, interactive communication rules, and OIG enrollment-volume scrutiny are driving a new wave of Medicare…
Self-Disclosing a Medicare Overpayment
Physicians who identify a Medicare overpayment can choose a straight refund, the OIG protocol, or the CMS SRDP, each carrying diff…
Building an Effective Compliance Program That Counts
OIG's seven elements and DOJ's evaluation factors, and what compliance officers need to document to prove a compliance program act…
UPIC Audits of Genetic Testing Providers
UPIC audits of genetic testing providers focus on cancer genomic panel necessity, telemarketing-driven physician orders, and kickb…