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IRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns

February 13, 2015 | Alert | By Theresa Carnegie, Ryan Cuthbertson, Carrie Roll, Jonathan Talansky

On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the physician practices as members of the corporations’ consolidated tax group for U.S. federal income tax purposes.
The Centers for Medicare & Medicaid Services (CMS) has published long-awaited changes to the Medicare Shared Savings Program (MSSP).

Proposed Rule Issued by OIG Realigns Its Enforcement Views with Health Care Reform Goals

October 9, 2014 | Alert | By Theresa Carnegie, Thomas Crane, Carrie Roll, Stephanie Willis

Fridays never seem to be slow in the health care regulatory world. On Friday, October 3rd, the HHS Office of the Inspector General (OIG) issued a highly anticipated proposed rule (the Proposed Rule) that provides amendments to the Anti-Kickback Statute’s regulatory safe harbors (AKS Safe Harbors) and adds protections for increasingly common payment practices and business arrangements under the Civil Monetary Penalty Law (CMP).

Health Care Enforcement in 2013: A Year in Review

January 13, 2014 | Advisory | By Hope Foster

In 2013, the U.S. Department of Justice, Health and Human Services Office of Inspector General, and other federal and state agencies continued to aggressively prosecute health care fraud and related offenses through criminal, civil, and parallel proceedings.
A recent federal appeals court decision addressing pleading standards for shareholder suits under Section 11 of the Securities Act of 1933, as amended, highlights the potential dangers of giving broad assurances of legal compliance in registration statements.

Health Care Enforcement in 2012: A Year in Review

February 25, 2013 | Advisory | By Samantha Kingsbury, Hope Foster, Jessica Sergi

Trends in health care enforcement during 2012 have been significant in reinforcing the government’s fraud investigation and recovery strategies. Health care fraud enforcement will likely intensify in the post-health reform era.
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