Law360 published an article by Paul Cirel concerning the increased scrutiny nontraditional health care programs are facing from government investigators for fraudulent billing practices.
In his article, Mr. Cirel, a partner at Todd & Weld LLP, examines recent enforcement actions against home health agencies for Medicare and Medicaid for fraud and abuse claims. From those actions as well as recent policy pronouncements of state and federal government agencies, he notes that "common threads" are emerging to guide providers in conducting internal audits or responding to a government investigation.
"In this closely watched environment," Mr. Cirel writes, "providers and their counsel will do well to anticipate the potential for either audit or investigation, and to consider a self-audit or at least a review of their own protocols and record-keeping practices, with an eye toward the type of conduct that the government has targeted."
Mr. Cirel concentrates his practice on health law, including representing healthcare clients in billing fraud and abuse investigations, as well as false claims actions.