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Wisconsin Health Law Posts
- Managing AI Risk: Governance, Hallucinations, Automation Bias, and Human Oversight
- What Part of Your Creative Workflow Needs Stronger Compliance Structure?
- Wisconsin APRN Modernization Act: Wisconsin’s New Nurse Practitioner Law
- The 7 Rules of Human-Led Creation: Protecting Originality in an AI-Assisted World
- Preserving Your Copyright When Using AI-Assisted Songwriting
- The New Creative Frontier: Human Authorship in a Hybrid Age
- Why Generative AI Creates Unique Governance Challenges
- AI Training Data and Copyright: Legal Risks and Vendor Contract Protections
- How Copyright Law Applies to Generative AI Training Data
- Human-Led AI Creation and AI Copyright Protection: A Practical Framework
- AI Governance Risks: AI Ethics, Compliance, and Oversight Strategies
- Organizational Drift in Artificial Intelligence Governance
- The Opacity Problem in Artificial Intelligence Deployment
- Cascading Dependency Risk in AI Systems: How to Govern the Hidden AI Supply Chain
- Applying PII Compliance Protocols to Artificial Intelligence Activities
- OSHA Citation Lessons: Written Safety Plans Required by OSHA Standards
- From Contract Signature to Continuous AI Governance in Third-Party Risk Management
- Corporate Practice of Medicine in Wisconsin: Why Structure Still Matters for Physician Practices
- Wisconsin Noncompete Bill Would Restrict Noncompetes for Medical Practitioners
- The Physician Board Member – Meeting Your Responsibilities as a Director
Categories
- Accountable Care Organizations
- Ambulatory Surgery Centers
- Anesthesiologists
- Antitrust in Healthcare
- Artificial Intelligence
- Behavioral Health
- Clinical Integration
- Compliance Issues
- Consierge & Cash-Based Practices
- Corporate Practice of Medicine – CPOM
- COVID-19 Resources
- Dental Practice
- Dental Practice Issues
- False Claims Act
- Fraud and Abuse
- Governance
- Health Care Contracting
- Health Care Legislation
- Health Law Practice
- HIPAA – Health Information Privacy
- Home Health
- Hospital Issues
- Legal Pulse Podcast
- Licensing
- Long Term Care
- Managed Care Contracting
- Medical Staff Organization & Structure
- Medicare and Medicaid
- Medicare and Medicaid Reimbursement
- OSHA
- Physician Contracting and Alignment
- Physician Issues
- Physician-Owned Hospitals
- Proprietary Right Protection
- Radiology Issues
- Reimbursement & Payment Practices
- Reimbursement Issues
- Self Disclosure Protocols
- Stark Law and Anti-Kickback Issues
- Telemedicine
- Uncategorized
- Wisconsin Government
- Wisconsin Health Laws
- Wisconsin Hospitals
- Wisconsin Long Term Care
- Wisconsin Physician Issues
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Category Archives: Stark Law and Anti-Kickback Issues
Podcast – ASC’s 1/3 Safe Harbor
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 12 – ASC’s 1/3 Safe Harbor Welcome to … Continue reading
Posted in Ambulatory Surgery Centers, Fraud and Abuse, Legal Pulse Podcast, Physician Issues, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws
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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
Posted in Compliance Issues, False Claims Act, Fraud and Abuse, Health Law Practice, Physician Contracting and Alignment, Physician Issues, Stark Law and Anti-Kickback Issues
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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
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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
Posted in False Claims Act, Fraud and Abuse, Medicare and Medicaid, Medicare and Medicaid Reimbursement, Physician Issues, Reimbursement & Payment Practices, Reimbursement Issues, Self Disclosure Protocols, Stark Law and Anti-Kickback Issues
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OIG Advisory Opinions on Gainsharing Arrangements Since 2018
By Fisher, JD, CHC, CCEP Client Alert: OIG Advisory Opinions on Gainsharing Arrangements Since 2018 Introduction to Gainsharing Arrangements As hospitals, health systems, and physician groups continue to pursue value-based care strategies, gainsharing arrangements remain an important—but highly regulated—tool for … Continue reading
Posted in Anesthesiologists, Clinical Integration, Fraud and Abuse, Health Care Contracting, Health Law Practice, Hospital Issues, Medicare and Medicaid, Medicare and Medicaid Reimbursement, Physician Contracting and Alignment, Physician Issues, Reimbursement & Payment Practices, Reimbursement Issues, Stark Law and Anti-Kickback Issues
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Podcast – Kickbacks in Cash-Based Medicine
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. In today’s episode, “Kickbacks in Cash-Based Medicine,” we dive … Continue reading
Posted in Compliance Issues, Consierge & Cash-Based Practices, Fraud and Abuse, Legal Pulse Podcast, Physician Issues, Stark Law and Anti-Kickback Issues
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Concierge Medicine Article Series | The Anti-kickback Statute in Concierge and Cash-based Medical Practices
By John Fisher, JD, CHC, CCEP The Concierge and Cash-Based Medical Practice Article Series explores the evolving landscape of healthcare delivery models that prioritize patient-centered care, transparency, and direct financial relationships between patients and providers. Through this series, readers will … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Physician Issues, Reimbursement & Payment Practices, Stark Law and Anti-Kickback Issues, Telemedicine, Uncategorized
Tagged anti-kickback statute, Concierge Clinics, Concierge Medicine, direct primary care, Telemedicine, wisconsin health lawyer
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CONCLUSIONS ABOUT DIRECT PRIMARY CARE AND CONCIERGE PRACTICES
Now is Not the Time for Complacency The concierge medicine and direct primary care movement represents a genuine and important evolution in how physician services are delivered in the United States. These models, at their best, offer patients more attentive … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Medicare and Medicaid Reimbursement, Physician Issues, Reimbursement Issues, Stark Law and Anti-Kickback Issues, Telemedicine, Wisconsin Health Laws
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THE OIG ADVISORY OPINION PATHWAY FOR CONIERGE AND CASH-BASED PRACTICES
For arrangements that are novel, involve significant financial investment, or present a unique structural profile without a clear safe harbor fit, the OIG Advisory Opinion process provides a mechanism for obtaining binding regulatory guidance. Under 42 C.F.R. § 1008.38, a … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Physician Issues, Reimbursement & Payment Practices, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, concierge practice, direct primary care, Medicare Reimbursement, wisconsin health lawyer
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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
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