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Health Care

Dollars to Donuts - Sunshine Audit Review

Although most physicians have heard about the Physician Payments Sunshine Act (the “Sunshine Act”) and have seen reports of the payments physicians have received from reporting drug and medical device companies, few physicians take the time to review or correct their own records. 

Many physicians…

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Is Your ASC Too Cheap?

The development and growth of ambulatory surgery centers (“ASCs”) has continued and even accelerated in recent years. Shifts in allowable cases from inpatient to outpatient, temporary closures of hospital outpatient departments because of COVID, and private equity funding have all bolstered this…

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What is a “Referral” Under the Anti-Kickback Statute?

Central to the practice of medicine, referrals are an important part of patient care.  Referrals are also a critical component when evaluating whether arrangements between parties violate the Anti-Kickback Statute (“AKS”), which prohibits knowingly or willfully offering, paying, soliciting, or…

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