Eric Rubenstein’s Weekly Wrap Up (08/29-09/02)

September 2, 2022

Boca Raton Chiropractor Sentenced To Four Years’ Imprisonment For $20 Million Health Care Fraud Scheme

Straw ownership is a huge challenge in healthcare fraud investigations. The creation of shell companies and nominal owners obscures the true ownership and thus, the true nature of the business. I worked many cases as an OIG agent where this was the standard. It can take a substantial amount of time to uncover the true ownership, and usually requires bank record analysis, corporate record filings and a slew of other documents to link the straw owners to the true business owners.

Charlotte Medical Device And Equipment Manufacturer Agrees To Pay Over $780,000 To Resolve Allegations Of False Claims Act Violations

Device manufacturers make devices, they do not create, interpret or formulate payment policies. Unfortunately, all too often device companies come up with “suggested billing, coding and documentation” guidance. This guidance is not worth the price of the paper that it is written on when provided to the buyer. It is always in the interest of the manufacturer to entice a potential buyer with all of the money that will be made by buying the device, billing for the device and how to go about that billing and coding. The advice of a manufacturer is not the word of the payor, regardless of what the sales representative shows the potential buyer. All of the benefits statements, accounts receivable documents and related financials are nothing to hang your hat on; if you bill for a device inappropriately, you as the provider are on the hook. It is good to see that manufacturers are being held accountable for their malfeasance.

Video: The Compliance Guy: Compliance and Legal Roundtable

Compliance and Legal Roundtable with Sean Weiss, The Compliance Guy, Attorney Colin Callahan of Flannery / Georgalis and Eric Rubenstein, Ret. OIG Agent of Advize Health. The Roundtable discussion explored Private Equity (PE) and the pitfalls of engaging both as the investor and as the portfolio company. 

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