Fraud and Abuse Laws

1. Consider the settlement inU.S. v. Halifaxand theCorporate Integrity Agreemententered into by Halifax Hospital Medical Center, which addresses methods for preventing Anti-Kickback violations.
2. What measures required by the Corporate Integrity Agreement do you believe will be most effective in preventing future violations?
3. Which, if any, do you think will be least effective or ineffective in preventing future Anti-kickback violations? Explain your reasoning.
4. What is a Medicaid Integrity Plan? Who is responsible for creating and maintaining it?What does it cover?
5. The Physician Self-Referral law (Stark law) prohibits physician referral to designated health services (DHS) in which the physician or family member has an ownership interest.As a health care administrator what could you do to monitor this?
6. The False Claims Act is often linked to billing problems such as upcoding, billing for non-medically necessary services,services not provided, unbundled services, etc.What billing strategies could you implement to lessen the likelihood for a False Claims Act problem?

Links:

AHLA (n.d.).Healthcare Fraud and Abuse, A Primerhttps://www.healthlawyers.org/events/programs/materials/documents/mm13/g_washlick.pdf

Comprehensive Medicaid Integrity Plan (CMIP):https://www.cms.gov/Regulations-and-Guidance/Legislation/DeficitReductionAct/CMIP.html

Halifax Health (n.d.).Community Health Needs Assessment. Retrieved fromhttps://halifaxhealth.org/wp-content/uploads/2019/09/community_health_needs_assessment_28329.pdf

United States ex rel. Baklid-Kunz v. Halifax Hospital Medical Center, et al.,No. 09-cv-1002 (M.D. Fla.)https://www.hortyspringer.com/documents/u-s-ex-rel-baklid-kunz-v-halifax-hosp-med-ctr-summary/.