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Steering Around Successor Liability in Health Care
HCFA Memorandum on Commerce
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advisory opinions alleged applicable appropriate areas attorney audit Baptist Medical Center billing company Blue Valley Medical civil client coding company's compliance committee compliance officer conduct conspiracy corporate cost report counsel court criminal dates being unknown defendants DAN ANDERSON defendants ROBERT DENNIS McCLATCHEY disclose documentation durable medical equipment effective compliance program employees False Claims Act Federal health fraud and abuse grand jury guidelines HCFA health care programs health care provider hospital hospital's http://www.dhhs.gov/progorg/oig/modcomp/thirdparty.htm 3/10/99 immunity implementation indictment individual inpatient Inspector investigation Johnson County Kansas kickback LAHUE and RONALD lawyer March 19 MARK THOMPSON Medicaid programs Medicare Medicare and Medicaid misconduct nursing home patients OIG believes OIG's Olathe outpatient overpayments payment penalties personnel physician physician self-referral policies and procedures potential Protocol provider agreement refer regulations reimbursement remuneration requirements RONALD H RONALD KEEL RUTH LEHR submitted transaction United States Code Valley Medical Group violation voluntary disclosure