civil monetary penalties

There are three most important federal anti-fraud healthcare laws that every provider should be familiar with:

  • False Claims Act (filing false claims),

  • Anti-Kickback Statute (offering/receiving remunerations for patient referrals, and providing free or discounted services), and

  • Physician Self-Referral Law (Stark law).

Government agencies have three vehicles to enforce these laws:

  • Exclusion Authorities,

  • Civil Monetary Penalties

Last week, I wrote about Walgreen’s settlement with state and federal governments for unlawfully soliciting Medicare and Medicaid beneficiaries to enroll in its Prescription Savings Club.

However, OIG has finalized a final rule extending safe harbors related to coupons, rebates, and other rewards from a retailer if:

  • The reward is offered on equal terms available