By: Aaron E. Kacer and Steven T. Lawrence On March 30, 2026, the U.S. Treasury and the Financial Crimes Enforcement Network (FinCEN) announced a new coordinated policy aimed at fraud schemes that intend to exploit Medicare, Medicaid, and other federal and state healthcare benefit programs.[1] The new policy includes (i) FinCEN advisory describing common healthcare…
The Arizona Controlled Substances Prescription Monitoring Program (“PMP”) was established in 2007 and provides the State of Arizona with a central database to track the dispensing of controlled substances. The PMP is designed to assist providers in making better-informed decisions and help “prevent the diversion and misuse of controlled substances at the provider, pharmacy, and…
AHCCCS has broad authority to exclude participating providers from its program. For example, AHCCCS may terminate a provider’s AHCCCS participation agreement if the provider fails to comply with their provider participation agreement, or with federal and state laws, rules, or regulations. AHCCCS must also suspend payments pending an investigation of a “credible allegation of fraud”…
Concurrent with the Covid-19 Public Health Emergency (“PHE”), the Arizona Health Care Cost Containment System (“AHCCCS”) modified requirements related to member enrollment and provider revalidation. Following the Consolidated Appropriations Act of December 2022, Medicaid is decreasing specific additional funding made available during the PHE. As a result, AHCCCS has returned to the regular renewal process…
On August 11, 2021, the U.S. Department of Justice (DOJ) issued a press release announcing a $350,000 settlement between the federal government, Cornell Scott Hill Health Corporation (“Cornell”), a Federally Qualified Health Center (“FQHC”), and the State of Connecticut to settle Medicaid fraud claims asserted against Cornell. As a FQHC, Medicaid pays Cornell for certain…
On April 26, 2020, the Centers for Medicare and Medicaid Services (CMS) suspended Medicare’s Advance Payment Program. CMS’s Accelerated and Advance Payment Program (AAPP) provides accelerated or advanced payments to Medicare providers and suppliers during national or public health emergencies. These expedited payments help provide funding when circumstances disrupt claim submission and claim processing. Providers…
The materials provided in this website are for informational purposes only and are not for the purpose of providing legal advice. Transmission of information from the ML website is not intended to create, and its receipt by you does not create an attorney-client relationship with ML or any of its individual attorneys or personnel.
If you elect to communicate with anyone at ML through this website, or otherwise, in connection with a matter for which we do not already represent you, your communication can not be treated as privileged or confidential. Do not transmit any information about any matter (and particularly not information you regard as confidential) that may involve you until ML has agreed to represent you, and you have received confirmation of that fact in the form of a written engagement letter.