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Health Care

CMS Takes into Consideration the “Totality of the Circumstances” in Withdrawing its Far Reaching Medicaid Fiscal Accountability Rule

On November 18, 2019, the Medicaid world was “rocked” when the Centers for Medicare and Medicaid Services (“CMS”) published a proposed rule titled Medicaid Fiscal Accountability Rule(“Proposed Rule”).  While intending to strengthen the fiscal integrity and promote transparency of the Medicaid…

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How Does My Compliance Program Measure Up?

While the goal of any organization is to avoid investigation by government agencies altogether, the reality is that health care providers operate in a highly regulated industry resulting in greater risk of encountering an enforcement action at some point.  Therefore, it is imperative to consider how…

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