Sub-Regulatory Guidance State of Play: Where We’ve Been and Where We’re Headed
This Featured Article is contributed by AHLA's Fraud and Abuse Practice Group.
- May 27, 2022
- Robert Yates , Deputy Attorney General, Indiana Attorney General’s Medicaid Fraud Control Unit
- Andrew Liebler , Alston & Bird
In between the islands of statutes and regulations is a vast expanse of sub-regulatory guidance informing the business operations of nearly every component of health care. As the scope and complexity of federal and state health care systems continues to grow—particularly during the COVID-19 pandemic—sub-regulatory guidance has become a central topic for health care practitioners, government enforcement authorities, and defense counsel grappling with the difficult question of how to interpret and comply with program laws, rules, and agency expectations.
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