Managing Fraud and Abuse Risks Through Effective Compliance Programs
This Feature Article is brought to you by AHLA's Hospitals and Health Systems Practice Group.
- January 01, 2024
- Justin K. Brown , Bass Berry & Sims PLC
- Dee D. Harleston , Bass Berry & Sims PLC
- Brianna R. Powell , Bass Berry & Sims PLC
- Morgan H. Tandy , Bass Berry & Sims PLC
Health care organizations operate in a challenging regulatory environment. A labyrinth of statutes, regulations, and sub-regulatory guidance, as numerous as they are complex, creates an environment full of risks. Chief among these are the risks arising from fraud and abuse laws. Violations of these laws—the federal Anti-Kickback Statute (AKS), Physician Self-Referral Law (PSL or Stark Law), Civil Monetary Penalties Law (CMPL), and False Claims Act (FCA), to name a few—can result in substantial financial penalties, exclusion from participating in federal health care programs, and other penalties, both civil and criminal.
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