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Posts Tagged ‘physician compliance’

Mandatory Compliance Program for Physician Practices – New Blue Paper

Wednesday, September 12th, 2012

Physician Practice Mandatory Compliance Programs

New Blue Paper on Compliance Programs for Physician Groups

It is no secret that the government is becoming increasingly aggressive in its enforcement efforts against health care providers.  At the same time, regulations are becoming more complicated.  The combination of these two forces means that many unknowing providers are being caught up in costly investigations of their practices.  The government is taking a “return on investment” approach to health care fraud and is seeing a good return on every dollar that they put into the efforts.  As a result, we cannot expect fraud enforcement to decrease any time soon.

 For this reason, it is important that providers, including medical practices, develop and operate systems to help them comply with governmental regulations and third party payer billing requirements.  The development of a formalized compliance program has become an indispensible part of the risk management process of medical practice.  Failure to maintain compliance can lead to an increase in reimbursement disputes, increased uncollectable fees, more demands for repayment, civil litigation and in extreme cases, potential criminal prosecution.

Ruder Ware has just published a new “Blue Paper” on development of Compliance Programs for Physician Practices.  Mandatory Compliance Program Blue Paper

Compliance Programs Come Center Stage As Government Tools Expand

Friday, April 20th, 2012

Health Care Compliance and Our Compliance Practice

John Fisher, CHC

Health care attorneys health lawThe current health care regulatory environment presents a high degree of risk to even the most well-intentioned provider.  Recent legal changes have made it even easier for the government to pursue what they believe to be improper activities.  The government is taking a “return on investment” approach to pursuing health care fraud and is coming out on the winning end of this game.  Reports state that the government collects approximately $15 for every $1 that they invest policing health care fraud.  In addition, Whistleblowers continue to bring a steady flow of cases against health care providers.  Even though there is a dispute over certain aspects of health care reform, the area where all ranges of the political spectrum appear to agree is on pursuing health care fraud.  Therefore, we cannot expect this climate of enforcement against health care providers to go away anytime soon.

 While the government continues with its “pay and chase” approach to health care fraud and overpayments, it is also integrating even more drastic measures into its bag of tools.  The government is now authorized to discontinue making payments to a provider altogether upon receiving any “credible allegation” of misconduct.  The allegation does not need to be proven to be true and there is not even a formal procedure to permit the provider to make its case.  Yet, the financial consequences of suspending payment can be devastating.

 Chances are very good that an individual provider will eventually have dealings with the government over some overpayment or fraud and abuse issue.  If you have not had to deal with an investigation, you are very fortunate.  Even the best intentioned providers will more likely than not need to deal with government scrutiny.  When that occurs, it serves the provider well to have an appropriately scaled compliance program that is being actively worked to identify risk areas, billing mistakes, and other possible difficulties.  Having an effective compliance program in place is the best way to turn the problem into something that is manageable, and turn it away from an enforcement action that can have grave consequences on operations and financial viability.

 At Ruder Ware, we have assembled a multidisciplinary team of attorneys to assist providers in compliance matters.  Our compliance team is lead by John H. Fisher, III, who is a seasoned health care attorney and is certified in health care compliance.  Our compliance team can assist providers through the process of structuring an appropriately scaled compliance program, reviewing existing compliance program for effectiveness, and assisting with ongoing operational issues related to compliance programs.

 Our compliance team brings a depth of experience in the wide range of compliance issues that affect various types of providers, such as the Federal False Claims Act, the Stark Law, Anti-Kickback Statute, Civil Monetary Penalties laws, and various legal and billing issues that pertain to the specific practice or provider.  We can suggest practical approaches for identifying specific risk areas and crafting plans to minimize risks in those areas.

 We are able to work with compliance departments to fashion methods for handling issues that arise through their compliance reporting systems, including the creation of corrective action plans.  We advise providers regarding identification, repayment of overpayments, and where necessary, self-disclosure of legal violations to the appropriate governmental agencies using self-disclosure protocols.

When compliance problems are identified, it is critical that providers take appropriate actions to make repayment, appropriately investigate, and craft a proper resolution that avoids reoccurring or deeper difficulties.  We are able to assist with these matters under the attorney-client privilege to determine the nature and scope of any discovered compliance concern.  We can direct investigations and take necessary steps to remedy the problem, all while maintaining client confidentiality.

As with any other legal issue, prevention is the best medicine.  Although we are equipped to assist providers as difficulties arise, we prefer to assist providers to ensure that their compliance programs are effective and appropriately tailored to the size and nature of their particular business.  Ruder Ware’s compliance team has experience conducting compliance effectiveness review and “gap analysis.”  This process involves in-depth due diligence review of matters relative to your compliance program, an assessment of the program, and specific recommendations aimed at making the compliance program more effective.

60 Repayment Rules, False Claims Act and Compliance Programs

Tuesday, March 13th, 2012

Proposed 60 Day Repayment Rules Push Providers Toward More Robust Compliance Programs

Health care attorneys health lawCMS has released a long awaited proposed rule defining provider obligations to report Medicare and Medicaid over-payments within 60 days of identification.  Section 6402 of the Patient and Program Protection Act created possible False Claims Act liability and possible program exclusion for the knowing concealment or avoidance of a repayment obligation.  The new proposed rule is intended to add definition to the general obligation that was included in the initial statutory provisions.  Section 6402 of PPACA requires providers to report and return over-payments within 60 days of identification.  The original statute broadly defined the provider obligations but did not provide specifics on several topics such as when an overpayment is deemed to be “identified” or how long providers were obligated to look back when identifying potential over-payments.

The Proposed Rule created an extremely onerous look-back period of ten years.  This means that providers will be obligated to report overpayment obligations that they discover which date back as far as ten years from the date of discovery.  The actual disclosure rules are somewhat less oppressive than the self disclosure rules that were already in place with regard to the Anti-kickback Statute and the Stark Law.  Nevertheless, many aspects of the proposed regulations, and in particular the ten year look-back rule, are likely to generate comments from affected parties. The specific requirements of the self disclosure rule leave much room for debate over several issues such as the level of detail that is required to be included in the disclosure.  There will certainly be a lot of debate at upcoming conferences that begin to dissect the specifics of the proposed regulations. 

The 60 day clock once an overpayment has been identified.  The proposed rule considers an overpayment to be “identified” when (i) there is actual knowledge that an overpayment exists, (ii) there is a reckless disregard or deliberate ignorance that an overpayment exists.  There will be a lot of debate over when someone obtains “actual knowledge.”  There will likely be even more debate over when someone begins acting in “reckless disregard” that an overpayment exists.  The “reckless disregard” standard involves an imputation of knowledge to an individual and will revolve over the facts that were present or should have been observed.  This requires a objective imputation of a subject standard of “identification.”  These areas of the law always involve much debate.  The definition that CMS chose for “identification” forces providers to be overly diligent in their proactive efforts to uncover billing inaccuracies.  Virtually any error that goes uncovered and could lead to a repayment could be imputed to the provider under the “reckless disregard” standard.  The entire standard contemplates the use of a diligent system of audits being put in place in order for a provider to demonstrate that they have not acted in deliberate ignorance or reckless disregard of the existence of an overpayment.  The standard that CMS set is just a further indication that the Federal government is attempting to push past the “pay and chase” approach of the past toward a system that requires providers to actively police themselves for errors.

To put this in perspective, failure to report an “identified” overpayment within 60 days opens the provider to liability under the False Claims Act.  The False Claims Act providers for penalties of three times the actual amount of the overpayment, plus between $5,000 and $11,000 per claim.  If a provider discovered a systematic error that may have led to a significant number of claims being overpaid, the amount of financial exposure under the False Claims Act can be very substantial; substantial to the point of presenting a grave threat to financial viability in some cases.  Under the Proposed Rule, reporting and repayment would be required for all  identified within ten years of receipt.  In the case of the discovery of a systematic billing problem, this could require repayment for the past ten years of claims.  If the False Claims Act obligation is applied to the entire look back period, the amount due grows exponentially.

If the proposed rule is finalized in its current form, it should have a very significant affect on compliance activities.  In order to meet the “reckless disregard” standard, providers will need to engage in very robust auditing and monitoring programs; in most cases much more extensive than are currently being utilized.  Some compliance officers tend to rank risk by the degree of potential consequences to the organization.  Risk identification is a function of two factors; the likelihood of a matter occurring and the degree of consequences.  What the CMS overpayment disclosure rules do, in conjunction with the False Claims Act damage computation, is to greatly increase the consequences of systematic billing errors.  The only way for a provider to prevent these errors, or at least create a plausible argument that it was taking appropriate steps to flush out errors, is to implement a robust auditing program.

Keep in mind that these rules do not only apply to large health care providers.  They also apply to individual and small physician practices and other small health care companies.  The potential impact on smaller organizations can be even more severe.  The recent health care reform law made compliance programs mandatory for most providers starting with nursing homes in 2013.  Mandatory compliance programs will extend to other types of providers as regulations are put in place.  In view of the proposed repayment regulations, providers of all size should seriously look at the areas of risk that apply to their operations and implement compliance programs that include an audit plan that is tailored to the provider’s specific risk areas.

Physician Compliance Programs – Specific Steps Necessary

Monday, December 19th, 2011

compliance attorney physician compliance issuesSpecific Steps Needed to Establish a Compliance Program for a Physician Practice

 The Compliance Guidance for Physician Practices and the Federal Sentencing Guidelines provide useful information concerning the process that is required to develop appropriate compliance programs.  A health care compliance attorney, preferably with demonstrated knowledge of the compliance process through appropriate certification in health care compliance, can also be a terrific asset to help you design a program.  I may be repeating myself, but it is extremely important that you do not simply adopt a “canned” program and expect it to reduce your risks or be effective in the event that the government comes calling.  It is extremely important that you follow a systematic process for assessing risk and tailor your compliance program to address precise risk areas that are identified through the process.  It is imperative that you document in detail the steps that you take to develop your program.  When developing your program, and later while operating your program, you should at all times assume that someday you will be called upon to defend the program and demonstrate that it indicates a meaningful organizational commitment to the specific compliance risks that you face in your unique practice environment.

 Initial Needs Assessment

 As mentioned above, a compliance program should be developed with consideration for the actual risks that are present in the specific practice.  This requires the practice to perform a formal analysis that is aimed at identifying specific risk areas.  The extent of the needs analysis will depend on the size and complexity of the practice.  Methods of performing the analysis will range from a full blown “gap” analysis with scoring of various risk areas down to a more simple employee questionnaire that asks for input concerning risk from the perspective of individual employees.  In smaller, less complicated practices, such as a simple primary care practice, the needs assessment will be relatively simple.  More complex specialty practices will touch on a much broad array of risk areas.  Each item identified through your needs assessment will need to be prioritized and appropriately addressed in the compliance program.

 Establish Line of Responsibility for Compliance Matters

 The Federal Sentencing Guidelines require the appointment of a single individual with responsibility for compliance in the organization.  The individual should be a “high ranking” individual with direct access to the Board of Directors or other governing authority.  Smaller physician practices will generally designate one of the physicians as compliance officers.   A member of administration may be named compliance officer in larger clinics. 

 Ideally, the compliance officer should not be in-house counsel because of potential conflicts between the differing roles of advocate and compliance officer.  An attorney has ethical obligations to zealously defend the organization.  This will sometimes mean that the best course of action from a legal standpoint may be to “deny and defend.”  This will never be an appropriate course of action from the standpoint of a compliance officer whose primary job is to prevent compliance problems.  The compliance officer will work to bring problems to the surface and disclose them when they are uncovered.  This will often conflict with the role of general counsel.

 Certainly general counsel plays an important role in compliance, but not as compliance officer.  Most general counsel are already busy providing legal services to the organization.  Placing compliance under general counsel makes compliance a secondary function of the general counsel and fails to demonstrate adequate commitment to organizational compliance.  The “dual role” compliance officer will appear to work until a problem arises.  Several cases involving “dual role” compliance officers have been investigated by the Federal government.  Once an investigation commences, the organization generally quickly abandons the dual role compliance structure and appoints a dedicated compliance officer.  In the most visible cases, the general counsel was actually forced to resign and the organization settled the case by entering a Corporate Integrity Agreement that required the division of general counsel and compliance function.

 A practice may wish to consider creating a compliance committee in addition to appointing a compliance officer.  Establishing a committee can be very helpful to the organization gaining physician buy-in and demonstrating that the organization is serious about compliance issues.  As a practical matter, the compliance committee involves more individuals in the compliance process and can make the task of the compliance officer much easier.  In larger organizations, establishing a compliance or ethics committee is strongly recommended.  Smaller organizations should consider fulfilling this task at the Board level through regularly scheduled discussions of compliance issues.

 Adopt Standards of Conduct

 An integral part of the compliance program is the standards of conduct.  The standards of conduct should include simply stated standards, in terms that can be understood by all levels of employees and others that deal with the practice that provide information concerning the commitment of the practice to compliance matters.  The Standards of Conduct are not the place to get into legalistic discussions of the various laws that could apply to operations or present compliance challenges.  The Code of Conduct should be a summary that everyone can understand and should reflect the general tone of the practice’s commitment to honesty, integrity and legal compliance.

 Oftentimes the Standards of Conduct will include a personal introduction or letter from the highest ranking individual in the clinic which briefly explains the purposes of the Standards of Conduct and the practice’s commitment to legal compliance.  This helps to set the tone within the practice that compliance and ethical behavior are a core value and principal of the practice.

 Creating Your Compliance Plan

The compliance plan itself will provide detail in the seven areas of an effective compliance program as set forth in the Federal Sentencing Guidelines.  The Compliance Plan will normally cover each of the seven areas.  Additionally, there may be a more detailed discussion of some of the laws that may apply to the specific practice.

 Setting Up Your Internal Reporting Mechanism

 One of the primary elements in a Compliance Program is the creation of a system that permits employees and others to provide information regarding potential compliance issues without fear of retaliation.  In larger organizations, multiple pathways permitting employees to make anonymous complaints should be maintained.  Oftentimes providers use 24 hour compliance “hotlines.”  Online reporting systems or “drop boxes” are also commonly used.  Whatever system is used, it is crucial that employee understand that they are encouraged to provide information and that there is a clear prohibition against others in the organization retaliating against them for providing information.  It should also be made clear to employees that wherever possible the identity of the person providing the information will be kept confidential.

 The establishment of the compliance reporting process and communication to employees that retaliation will not be tolerated is a central element to an effective compliance program.  Such a system will help the practice obtain valuable information, hopefully early on, before the issue becomes a big problem.  Additionally, the openness of the program will send a strong signal to the outside world, such as government regulators, that the organization takes compliance seriously. 

 If information is obtained through the hotline system it must be taken seriously.  Certainly not every piece of information will be reflective of a serious compliance problem, and an employee could potentially have other motives for making a compliant.  Regardless, it is crucial that the information be acted upon and that the action be documented.  If the compliance officer concludes that there were alternative motivations for the complaint, that fact should be substantiated and documented.  If an objective investigation indicates that there could be a compliance issue, the matter needs to be pursued through an appropriate outcome.  Depending on the circumstances and the result of a thorough investigation, the outcome could range anywhere from additional training through a self disclosure to the government.

 Internal Compliance Policies and Procedures – Enforcement

 One of the elements required by the Federal Sentencing Guidelines and described in all of the OIG industry specific Compliance Guidelines is that the Compliance Program include a mechanism to deal with compliance problems as they are discovered.  In some cases the appropriate action may be a change in policies and further education.  In more extreme cases of compliance violations should lead to employment discipline of various degrees depending on the nature and extent of the violation.  Other cases will require full disclosure to the Federal government and repayment of overpayments and possible penalties.

 It is important that your compliance program fit seamlessly with your employment policies.  Part of developing a compliance program is adopting suitable employment standards that let employees know what to expect from an employment standpoint if they are found to be engaged in compliance infractions.  These policies need to be communicated to employees as part of their training, both so they know the potential employment implications of compliance infractions, and so employees understand how seriously compliance issues will be taken by the organization.

 Governing Board Approval of Compliance Plan and Policies

 When it comes to compliance matters, the “buck stops” with the board of directors or other governing body of the organization.  The governing body should be involved in the creation and adoption of all policies and procedures.  The governing body and top management should take all actions necessary to make compliance a top priority within the organization.  The board should issue an initial resolution regarding compliance at the inception of the process of creating a plan.  The resolution should indicate the commitment of the governing body to compliance.  It should also allocated sufficient funding to the establishment and operation of the compliance program.  All of these actions indicate the organization’s commitment to compliance.

 During the development stage, the governing body should be kept in the loop.  Frequent reports should be provided to the governing body and input into the process should be provided by the governing body.  The governing body should approve the steps that are taken in writing.  If further direction comes from the governing body, it is recommended that the direction be placed in writing.  This will indicate the ongoing input from the governing body and further solidify the organization’s commitment to compliance.

 The governing body should also assist with other professionals in the organization “buying in” to the compliance efforts.  It is very helpful for the governing body to be proactive in compliance issues and set the tone for the “compliance spirit” within the entire organization.

 Internal Documentation and Systematic Approach 

 It is extremely important for the organization to take a systematic approach to both developing and operating a compliance program.  Each step of the formation process, from the initial planning stage through final implementation, should be documented with a great deal of detail.  The information should be presented to the governing body for review periodically through the implementation stage and the governing body should approve and adopt the information and provide additional suggestions and directives to the compliance officer.

 When establishing and operating your compliance program, keep in mind that it is very possible, if not highly likely, that someday you will be called upon to defend the actions that you took to establish and operate the program.  This is a very useful mindset to have while you are performing compliance functions.  We often advise organizations to act as if the organization is actually under a Corporate Integrity Agreement and to document each steps as if they are providing the information directly to the government.

 Educating and Training Your Staff

 Another key element of an effective compliance program is to have an ongoing education and training program for employees.  Training should occur at the inception of the program and upon commencement of employment by any new employees.  Additionally, the organization should adopt an ongoing training program to provide period refreshers of basic issues and the requirements of the program.  Additionally, topic-specific training should occur based on compliance risks or problems that are identified through the operation of the compliance program.

 Ongoing Monitoring, Auditing and Assessment

 It is important that the compliance program be seen as a continual process within the organization.  Adopting a compliance program and then leaving it sit on the shelf will be of little if any effect.  In fact, failing to adopt compliance as a process rather than a static “form” can present the organization with more risk than failing to adopt a compliance program at all because the compliance program that is not actively “worked” sets expectation and requirements that will not be met.

 The organization should adopt an effective ongoing process to monitor and audit the organization for compliance difficulties.  Risks areas that are identified by the monitoring process need to be reinforced with amendments to the compliance program, action by the governing body, potential internal discipline, additional training, and in extreme cases, self reporting to the federal government.

 In The End

 The process of developing an effective compliance program will not be without some pain, internal resistance, and resources.  The payoff will often not be as apparent as the effort that it takes to develop and operate an effective program.  The risks you are avoiding can be very difficult to see or quantify.  However, the failure to confront and mitigate those risks can be devastating to your organization.  Repayment obligations for false claims are generally three times the amount of the claims plus $15,000 per claim.  It is shocking how fast the penalties add up.  Extreme cases of fraud can also lead to criminal investigation and prosecution.  Recently enacted health care reform legislation makes it easier in a number of ways for the government to bring criminal prosecutions in the health care area.

 Now that compliance programs are becoming mandatory for most providers, including physician practices, it is necessary for providers to confront these issues.  Do not make the mistake of taking this task on in a half-hearted manner.  The result will not provide you with any of the benefits of an effective compliance program and can actually hurt you if a problem ever arises.  Even though the date for adopting mandatory compliance plans for physicians is not yet upon us, you should start now to assure that your program is effective and that you have time to develop the appropriate “buy-in” by professionals in your practice.  The proper process as identified above cannot be accomplished by taking “canned” compliance policies and adopting them.  You must go through the steps necessary to develop a meaningful program.

Elements of An Effective Compliance Program

Monday, December 19th, 2011

Basic Elements of An Effective Compliance Program

Developing a compliance program that will be effective to reduce internal and external risk is a “practice specific activity.”  There is no “one size fits all” compliance program and there is no good “off the shelf” form solution.  There are certainly vendors, consultants and lawyers out there who would like you to believe that you can take a form, make a few changes and fill in a few blanks, and create an effective compliance program for your organization.  This approach really misses the point of what is required in order to develop and effective program.  Certainly the written plan is an important and necessary part of the compliance effort.  However, even more important is the process that you go through to develop the compliance plan.

 Establishing a compliance program requires you to perform a risk assessment on your specific organization and document the outcomes of that assessment.  The risk assessment could take many forms.  Compliance professionals talk about a “gap analysis” which is an approach to help determine the vulnerabilities of your organization.  A lawyer or compliance professional that has specific training and background in performing legal risk analysis can help you design an appropriate risk analysis process.  The primary point here is that this process needs to be organization specific rather than based on a pre-canned form.  You need to score your areas of risk and provide emphasis to appropriate areas of risk that are identified through your risk assessment.

 All compliance programs will have language regarding compliance with fraud and abuse, anti-kickback statutes, HIPAA and other health care laws.  It means virtually nothing to simply adopt a pre-canned policy without backing the policy up with the process that the practice went through to identify the specific risks that it faces given the specific nature of its practices, size, and specific personalities involved in the operation.

 As mentioned above, the Office of Inspector General has issued general industry guidance on compliance program development and one such guidance relates to physician practices.  This guidance, plus the general requirements of the Federal Sentencing Guidelines, provide general elements that are necessary to make a compliance program effective.  There are generally seven (7) basic core elements that are required of an effective compliance program including:

  •  Adoption of written guidelines and policies to promote the organization’s commitment to compliance;
  •  Identification and appointment of a high ranking individual within the organization to serve as compliance officer;
  •  Establishment of anonymous reporting systems, preferably through multiple pathways, to encourage individuals to make complaints regarding compliance items without fear of retaliation;
  •  Effective education and training programs for all levels of employees and others with close relationships to the organization;
  •  Ongoing auditing systems to assess the effectiveness of the compliance program and to provide input into areas that require additional emphasis;
  •  Mechanisms to enforce the requirements of the compliance program and to discipline employees for violations of the organization’s commitment to compliance; and
  •  An ongoing system of program modification based upon audit, feedback and experience that can further adapt the compliance policies to the specific issues faced by the organization.

 Establishing Commitment From the Top of the Organization

 An important and often overlooked aspect of developing a compliance program is the need to obtain commitment from the top of the organization.  Many times in a physician practice this will mean the physician owners of the practice.  It is important that the physician have a clear understanding of the need and benefit of establishing a focused compliance program.  There will inevitably be initial expenditures involved with establishing a compliance system.  In some cases it may even necessitate retaining additional staff.  There will almost certainly be fees to outside attorneys and consultants if the organization is not large enough to hire the needed expertise internally.  It is important that sufficient resources be allocated to compliance and that the physicians and administration understand that in the long term, these expenditures will pay off by reducing the risk of institutional compliance problems.  The difficulty is that if the compliance program works to reduce risks, there will never be a serious event that proves the benefit of the expenditures.  However, if an event occurs in the future and there is no compliance program in place, the regrets will be very deep because compliance issues are much more difficult to solve if there is no compliance plan in place.

 As a practical matter, the institutional “buy-in” is often the most difficult hurdle to overcome.  It is somewhat easier now that compliance plans are becoming mandatory.  Yet there is still risks associated with under-funding compliance activities or providing enough resources to do the “bare minimum” when it comes to compliance due to a reluctant attitude on the part of physician leaders who are now being forced to develop compliance programs that they have not fully embraced. 

 Certain groups may be in a position that they have not been dependent upon institutions who have implemented compliance programs.  Some practices completely reject policies and procedures of any kind that could bind the physicians in their practices.  These organizations present the greatest challenges and unfortunately the greatest potential risk of violations of federal and state laws occurring due to the low level of leadership embracing appropriate compliance activities.  Even as these groups are forced to adopt compliance programs, they present the greatest residual risk because of a low level of physician commitment.

 We suggest that physician practices begin the process of implementing formal compliance programs immediately to provide more time to gain physician commitment and appropriately assess the risks associated with the specific practice.  It takes a great deal of time to develop a system for establishing compliance programs, perform a “gap analysis” or other baseline analysis, perform employee interviews and take other steps to identify specific risk areas.  Developing a compliance program is much more than simply adopting a form compliance program.  Even though the precise effective date that compliance programs will become mandatory for physician practices has not yet been set, providers should consider this time a gift to permit them to develop appropriate policies rather than a reprieve.

About The Author

Health care attorneys health lawThis article is part of a multiple part series by Health Care Attorney John Fisher, CHC on compliance programs for physician practices.

John Fisher, JD, CHC  is a seasoned health care attorney and is certified in Health Care Compliance by the Health Care Compliance Association.  Mr. Fisher is available to assist physician groups and other health care providers nationwide in the development and operation of Compliance Programs.

Mr. Fisher has significant experience in the various legal and regulatory matters that are faced by physicians including the Stark Law, Anti-Kickback Statute and Safe Harbors, Medicare and Medicaid reimbursement rules, HIPAA, False Claims Act, antitrust laws, employment laws, contract matters, business ventures and laws governing financial relationships between physicians, and others.

Mr. Fisher practices with the Ruder Ware law firm in Wausau, Wisconsin.  His practice on compliance and Federal Law issues is nationwide.

John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
500 First Street, Suite 8000
P.O. Box 8050
Wausau, WI 54402-8050

Tel 715.845.4336
Fax 715.845.2718

Ruder Ware is a member of Meritas Law Firms Worldwide

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