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405.986) or “reliable evidence” of fraud or “similar fault” (as defined in 42 C.F.R. Notable Omissions from Proposed Rule CMS declined to adopt previously proposed amendments to the standard for “identified overpayments” under Medicare Parts A, B, C, and D. 2010) (quoting S. 3729(b)(1)(A) of the False Claims Act (“FCA”).
Global billing or collaborative care arrangements are not per se violations of the Anti-Kickback Statute, however, there is greater fraud and abuse risk in these types of arrangements unless there is active, ongoing monitoring for compliance. Million To Resolve Health Care Fraud Allegations | United States Department of Justice [3] See Defs.
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