We advise clients from virtually all segments of the health care industry, such as health systems, hospitals, academic medical centers, physician groups, long-term-care providers, home health agencies, hospices, behavioral health providers, pharmacies, laboratories, and allied health professionals. These cases generally involve compliance matters relating to Medicare, Medicaid, Tricare, and other federally funded health care programs.
“Counsel on Demand” ready reference with rapid response times
Advice on complex issues
Litigation
Defense of investigations and audits
Voluntary disclosures and repayments
Interactions with stakeholders
Dealing with hostile third parties
Regulatory counseling
Investigations
“Compliance on Demand” ready reference with rapid response times
Compliance program assessments and enhancements
Transactional due diligence
Acting as "Turnaround Compliance Officer" when there have been compliance challenges -- we help organizations to get on the right track.
Design and execution of claims audits
Interim Compliance Officer
Interim or overflow in-house Counsel
Fractional Counsel or Compliance Officer
Virtual or part-time roles for developing organizations
Sometimes there are conflicting viewpoints or a lack of clarity about how to handle a challenging situation. We offer independent, objective "second opinions" to facilitate a path forward:
Assessing whistleblower / False Claims Act matters
Reviewing proposed arrangements
Frank serves a mentor and champion for several legal and compliance professionals
Curriculum development using innovative platforms
Presentations to boards and senior leadership on legal, compliance, and governance topics
Assistance with establishing and maintaining organizational culture
Large health system in several False Claims Act (FCA) investigations by the Department of Health and Human Services – Office of Inspector General (HHS-OIG) and the Department of Justice (DOJ). The investigations were resolved favorably.
National medical group in a state OIG fraud investigation alleging improper Medicaid billings.
Several health care entities in voluntary disclosures to the HHS-OIG and the State Medicaid Fraud Agency.
Statistical audits relating to claims for reimbursement, calculation of potential overpayments, and voluntary repayments.
Prominent academic medical center in an investigation by the state insurance commissioner regarding claims submitted to commercial payors under the California Insurance Fraud Protection Act (IFPA).
Large medical group in federal and state investigations and actions involving allegations of violations of the corporate practice of medicine prohibition and corresponding False Claims Act allegations.
Multiple clients in False Claims Act lawsuits that alleged false billings to federal health care programs.
Compliance program assessments for an array of health care organizations.
Presentations to boards, senior leadership, physicians, and employees on many health care compliance issues.
Hospice providers in federal investigations and audits.
Home health agencies in federal and state investigations and audits.
Internal investigations for multiple health care providers relating to reimbursement, alleged false claims, potential retaliation, physician arrangements, and related issues.
Hospital systems defending against Recovery Audit Contractor (RAC) and other third-party payor audits.
Operators of long-term-care facilities in parallel state and federal fraud investigations.
Physician group in a False Claims Act qui tam suit brought by a disgruntled third party.
Academic medical center in a DOJ False Claims Act investigation relating to billings to federal health programs.
Major pediatric health systems in regulatory, reimbursement, and fraud and abuse counseling.
Physician group in its defense against a health insurer alleging that certain services were medically unnecessary and therefore not reimbursable.
Allied health providers embroiled in parallel state and federal administrative, civil, and criminal investigations into alleged billing for medically unnecessary services.
Pharmacy provider in a diversion investigation led by the DOJ and Drug Enforcement Administration.
Imaging provider, providing regulatory, reimbursement, and fraud and abuse counseling and advice on strategy and regulatory compliance relating to joint ventures with a health system.
