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OIG Revises Its Provider Self-Disclosure Protocol
Matthew E. Albers,Stephanie S. Angeloni,Jolie N. Havens, April 24, 2013
On April 17, 2013, the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) issued a notice completely revising its Provider Self-Disclosure Protocol (SDP). OIG originally published the SDP in 1998 to establish a process for providers to voluntarily...

CMS Releases Final Rule Regarding Physician Payment Sunshine Act
Stephanie S. Angeloni,Jolie N. Havens,Melissa James Jackson, March 19, 2013
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule on the Physician Payment Sunshine Act. The final rule imposes new reporting requirements on group purchasing organizations (GPO) and manufacturers of drugs, devices, biologicals or medical supplies for which...

FDIC Warning
J. Bret Treier, September 5, 2012
As we have previously noted, bank officers, directors and legal counsel should pay heed to the FDIC’s warning in its Financial Institution Letter dated March 19, 2012 (FIL-14-2012), that copying and removing financial institution and supervisory records from an institution "... is a...

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