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Michael A. Cassidy


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2022 Federal Compliance Enforcement Outlook

Michael A. Cassidy,, (412) 594-5515

There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas:

  1. The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as a foundation for False Claims Act enforcement.
  2. Furthermore, the reinstatement of the Yates memo of 2015 by the Deputy Attorney General Lisa Monaco’s Memo in October 2021 returns to the policy of individual liability for corporate misconduct.

There is general consensus regarding the resurgence of target, probe and educate (TPE) audits.  I have attached a link from the CMS website which provides an outline of the process and a humorous but misleading YouTube video regarding the alleged simplicity and intended fairness of the process.

We also expect significant audit activity around the new shared service billing rules for Evaluation and Management (E&M) visits which provide, the visit should be billed by the physician or physician assistant who provided the substantive portion of the visit, i.e. which is defined as more than half of the total time spent, and that both practitioners must be in the same group.  This may not be problematic if the visits are conducted separately and it’s accepted that the PA will be doing the billing.  However, when the visits are conducted jointly, so that the physician and the PA are both present, the physician should have an understanding of how the billing will be done, especially in a large group or system arrangement when the physician is relaying upon WRVU productivity.

For more information, contact Mike Cassidy at or (412) 594-5515. Visit our Med Law Blog here.

January 20, 2022

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