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…
Physician groups are frequently approached with “business opportunities” that sound routine, such as equipment leases, administrative services agreements, space rentals, and networking events. But all too often, those offers are really just dressed-up referral schemes that can land physicians in trouble. Two recent federal cases are important reminders that when it comes to vendor relationships,…
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On April 3, 2020, CMS published an Interim Final Rule (“IFR”) implementing a number of temporary waivers regarding various Medicare requirements, including telehealth. The IFR builds on the guidance CMS issued on March 30, 2020 and provides a sweeping set of additional new rules and waivers of federal requirements applicable during the during the COVID-19…
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