Category Archives: False Claims Act

Block Leasing of Group Practice Facilities – Anti-Kickback Statute Risks

By John Fisher, JD, CHC, CCEP Client Alert – Healthcare Block Leasing, Anti-Kickback Statute Risks, and AKS Safe Harbor Compliance Healthcare block leasing arrangements—where a group practice, physician organization, or other healthcare provider leases defined blocks of space in a … Continue reading

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What Is The Different Between Fraud, Abuse, and Criminal Conduct

By Fisher, JD, CHC, CCEP Fraud, Abuse, Overpayment — When Does a Mistake Become Fraud? Why Enforcement Matters Anyone involved in the health care system should understand that the federal government continues to devote significant resources to the investigation and … Continue reading

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Annual Health Care Fraud and Abuse Control Program Report

 2026 Health Care Fraud Enforcement Update: Compliance Risks, False Claims Act, and Medicare Advantage Health care fraud enforcement is no longer a distant risk reserved for bad actors on the margins of the industry. In 2026, health care providers, suppliers, … Continue reading

Posted in Compliance Issues, False Claims Act, Fraud and Abuse, Reimbursement & Payment Practices, Self Disclosure Protocols, Stark Law and Anti-Kickback Issues, Telemedicine | Comments Off on Annual Health Care Fraud and Abuse Control Program Report

Key Elements for Medical Practice Policies: Incident-to Billing, Physician Supervision, and False Claims Act Enforcement Risk

Understanding Compliance Requirements for Healthcare Providers Medical practices face a complex landscape of billing and compliance regulations. Three critical areas—Incident-to Billing, Physician Supervision, and False Claims Act Enforcement Risk—demand careful attention when crafting practice policies. Establishing clear guidelines not only … Continue reading

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Podcast – ASC Compliance 2026 – Complying With the New Regulations

Legal Pulse: Healthcare Edition Welcome to Legal Pulse: Healthcare Edition, the podcast where we explore the intersection of law and medicine to keep you informed on the latest developments and trends. Episode 7 – ASC Compliance 2026 Welcome to “ASC … Continue reading

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Dermatology Fraud Risk Areas – Impossibly Long Days

By John Fisher, JD, CHC, CCEP Dermatology Billing Risk — Incident-to Supervision and Impossibly Long Days Executive Summary This compliance brief summarizes a dermatology enforcement matter involving alleged improper “incident to” billing, failure to supervise services, and billing patterns reflecting … Continue reading

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Federal Government Will Seek Dismissal of False Claims Act Cases That Lack Merit

By Fisher, JD, CHC, CCEP False Claims Act Enforcement Priorities in 2018 Overview The False Claims Act (FCA) remained the federal government’s primary civil tool for combating fraud against taxpayer-funded programs in 2018. Although the statute dates to 1863, when … Continue reading

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Podcast – Physician Verbal Orders Decoded

Legal Pulse: Healthcare Edition Welcome to Legal Pulse: Healthcare Edition, the podcast where we explore the intersection of law and medicine to keep you informed on the latest developments and trends. Episode 6 – Physician Verbal Orders Decoded Welcome to another … Continue reading

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“Incident to” Billing Rules Clarified by CMS for 2026

By Fisher, JD, CHC, CCEP Incident-to Billing, Physician Supervision, and False Claims Act Enforcement Risk In the Client alert health care and compliance attorney John Fisher discusses the current CMS incident-to billing requirements; recent False Claims Act enforcement updates; incident-to … Continue reading

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PRACTICAL COMPLIANCE FRAMEWORK — WHAT COMPLIANT PRACTICES DO COMPLIANT DPC PRACTICES USE

Effective AKS compliance in a concierge or DPC practice is not a matter of checking boxes on a form or obtaining a valuation letter. It requires a systematic, practice-specific analysis of every financial relationship that implicates the statute, implemented through … Continue reading

Posted in Compliance Issues, Consierge & Cash-Based Practices, False Claims Act, Fraud and Abuse, Physician Issues, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws | Comments Off on PRACTICAL COMPLIANCE FRAMEWORK — WHAT COMPLIANT PRACTICES DO COMPLIANT DPC PRACTICES USE