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Health Care

The Yates Memo and Warner Chilcott – Fallout from the Trial

Following up on a previous client alert item, a federal jury recently found W. Carl Reichel, former president of Warner Chilcott, not guilty on June 17, 2016 of conspiring to pay kickbacks to doctors in exchange for writing prescriptions. The jury…

The Supreme Court Endorses "Implied Certification"

Hospitals which have discovered violations in their submissions for payment under Medicare and Medicaid may now pause before reporting the mistake and determine if the violation was “material” to the government’s conditions for payment. If the…

CMS Clarifies Access to Documentation as a Condition of Payment

Earlier this year, CMS published a Medicare notice titled Clarification of Ordering and Certifying Documentation Maintenance Requirements (Change Request 9112), which clarifies the term "access to documentation" in the Medicare Program Integrity…