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The ProviderTrust Blog

Your source for healthcare compliance news, advice from industry experts, and all things related to OIG exclusions.

OIG Exclusion List, OIG, exclusion list, exclusion, OIG Exclusion

Exclusion List Update! Hey Doc, Is That YOUR John Hancock?

Posted by Michael Rosen, ESQ on Thu, Jan 05, 2017

Exclusion Update!

NY Physician Agrees to 5 Year Exclusion

On December 9, 2016, Dr. Michael Esposito agreed to be excluded from participation in all Federal health care programs for a period of five years under 42 U.S.C. § 1320a-7(b)(7). The OIG's investigation revealed that Dr. Esposito forged the signature of another physician on prescriptions for medications for himself and another person that were paid for by the Medicare program.

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OIG Exclusion List, exclusions, exclusion list, department of justice, exclusion, OIG Exclusion

Deputy Yates Has Something to Say...Yates Memo and the Department of Justice

Posted by Michael Rosen, ESQ on Thu, Dec 08, 2016

Yates Memo

Deputy Attorney General Sally Yates issued a sweeping and telling memo on September 9, 2015. The purpose of the Memo, issued a day after she gave new guidance to Department of Justice (DOJ) attorneys - outlining the importance of individual accountability in DOJ prosecutions, was to articulate several changes to DOJ policy, particularly regarding the definition of cooperation credit for corporations. 

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The gist of the sweeping memo was to alert prosecutors that punishment should reach those who perpetrated the fraud themselves, and not just a fine to the corporation.  This brings personal accountability and responsibility to a whole new level.

Deputy Yates wants you to know that the Justice Department is serious about accountability of bad actors and that individual accountability is real. She wants to make the marketplace a "level playing field".

Recently, Sally Yates provided more insight into the "Yates Memo"as it has become known.  

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OIG Exclusion List, OIG, Fraud and Abuse, compliance, false claims act, exclusion list

Avoiding Whistleblowers- developing an effective and safe place to disclose

Posted by Mike Rosen on Tue, Sep 20, 2016


Think back to your first PE class in elementary school or your proudest moment in high school and the winning goal for that state championship game. Then, there is that dreaded whistle from the referee.  Suddenly, everything stops for the man in the stripped uniform and the power to stop everything in its tracks (the whistle). What will happen? What did he/she see that commanded a stop of the game?

Ok, now that I have your attention (and maybe that cloud nine moment in time), that whistle sometimes is not bad and signals a chance to check on a key play or issue.  This blog will address two points on whistleblowing in healthcare: (1) How to develop a safe environment for self disclosure and (2) the impact of a whistleblower action on your organization. 

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