Fraud & Abuse
Sequel provides counsel on compliance with federal and state healthcare fraud and abuse statutes, including the federal False Claims Act, criminal HealthCare Fraud Statute, Stark Law, and Anti-Kickback Statute; and state anti-kickback, patient brokering, and fee-splitting statutes.
Federal and state lawmakers are increasingly introducing and passing new fraud and abuse statutes that either can be very broad or target certain healthcare sectors. As a result, compliance programs can quickly become out of date, exposing organizations and providers to risk.
Whether clients need rapid response, a thorough business analysis and risk assessment, or development of a comprehensive compliance program, we help them stay on the cutting edge.
- Anti-Kickback Statute safe harbor analysis and compliance
- Equipment and space leases
- Personal services and management contracts
- Referrals
- Discounts
- Best practices development
- Business operation reviews and recommendations
- Compensation agreements
- Between addiction treatment programs and recovery residences (sober homes)
- Between clinical laboratories and healthcare organizations and ordering providers
- Between clinical study sponsors and study participants and providers
- Between marketing entities and healthcare organizations
- Fair market value analyses
- Pass-through billing
- Compliance program development
- Corporate structure and affiliations
- Corrective action plans
- Due diligence reviews
- Internal investigations
- Leases between healthcare organizations and other providers
- Marketing services agreements
- Medical necessity analysis and documentation
- Clinical laboratory services
- Coding and claims submission
- Frequency of testing
- Laboratory requisition forms
- Testing methodology
- Definitive, quantitative, or confirmatory tests
- Presumptive or qualitative tests
- Test selections (analytes and metabolites for drug detection)
- Timely review and use of results
- Ordering provider attestation statements
- Controlled medication storage, prescribing, dispensing, administration, disposal, and returns
- Provider and staff training
- Risk analyses
- Service agreements
- Clinical laboratory services
- Marketing services
- Phlebotomy and specimen collection services