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Fraud and Compliance Forum 2021

Schedule

We are excited to bring you this portion of the program in person, September 30-October 1 at the Renaissance Baltimore Hotel. The in-person program will include 11 in-depth breakout sessions and lots of time for networking with your colleagues.

Benefits of the In-Person Program

  • After a year of virtual programming, you will finally be able to step out from behind your computer and network face-to-face with other health law professionals.
  • Attend interactive breakout sessions, enriching your learning and engagement.


In-Person Program | September 30-October 1 | Baltimore, MD

AHLA is committed to providing a safe and healthy environment for program participants and staff. AHLA has adopted preventative measures to reduce the potential spread of the COVID-19 virus, including requiring masks, and is following guidance provided by the US Centers for Disease Control and local authorities. Attendees are also expected to do their part and abide by AHLA’s Duty of Care.


Thursday, September 30, 2021 

2:00-5:00 pm
Registration and Check-In
4:00-5:00 pm
Networking Reception, sponsored by HealthCare Appraisers, Inc.
(This event is included in the program registration. Attendees, faculty, and guests are welcome.)

 


Friday, October 1, 2021

7:00 am-5:30 pm
Registration and Information
7:00-8:00 am
Continental Breakfast
(This event is included in the program registration. Attendees, faculty, and guests are welcome.)
8:00-9:30 am General Session

8:00-8:15 am
Welcome and Introductions
John E. Kelly, Program Planning Co-Chair
Albert Shay, Program Planning Co-Chair

8:15-9:00 am
1. General Session
OIG Update

Gregory E. Demske
Robert K. DeConti
Lisa Re
Submit a Question
The HHS Office of Counsel to the Inspector General executive team will discuss current developments and priorities of OIG, including discussion of:
 Health care fraud enforcement and compliance
 Guidance to the health care industry
 Pandemic-related topics

9:00-9:30 am
Promoting Coordinated, Comprehensive Oversight of Federal Pandemic Relief and Response Efforts​
Robert A. Westbrooks
 The Role of the Pandemic Response Accountability Committee in Providing Transparency and Fighting Fraud
 Insights and Observations from the PRAC’s First Year
 Crowdsourcing for Success

9:30-10:00 am
Coffee Break
Exhibits Open–Meet the Exhibitors
10:00-11:00 am   

2. Investigation Hydras: Navigating Complex Issues in Internal Investigations
(not repeated)
 John H. Lawrence
Michael J. Regier
Jonathan A. Porter

Conducting an internal investigation in a health care provider organization can be anything but simple or straightforward. This panel will feature government, in-house, and defense counsel perspectives on challenging issues which can arise during internal investigations, and how practitioners can work through those issues with their clients. The discussion will draw from the panelists’ specific experiences and will include discussion of the following topics, among others.

  • Investigation scope—how to ensure the investigation is appropriately comprehensive, but does not become too expansive
  • Use of experts—when and how to use expert assistance (both internal and external), and how to mitigate the risk that today’s expert could become tomorrow’s qui tam relator
  • Quantifying the unquantifiable—evaluating complex billing and claims submission issues when quantification of an overpayment is difficult (or “impossible”) to achieve, and considerations in preparing for a disclosure
  • To disclose, or not to disclose—deciding whether to make a voluntary disclosure, when to do so (before, during or after the investigation?), and to whom the disclosure should be made
 

3. Implementing Value-Based Care: Stark
Troy A. Barsky
Albert W. Shay

  • Stark Law Reform: Why the changing health care industry compelled CMS to make needed reforms to this important fraud and abuse law
  • The key changes to the Stark Law’s value-based payment exceptions and the importance of understanding the scope of applicable definitions
  • Other revisions to the regulations designed to accommodate value-based arrangements
  • Practical examples of potential value-based payment arrangements and how these the revised regulations will either help or hinder innovation
  • Compliance guidance and advice for providers seeking to ensure compliance in this changing regulatory landscape
 

4. Avoid the Long-Haul Risks of COVID Relief Funds
Joseph V. Geraci
Chris Schrank

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law, making available $2.2 trillion in relief funds–of which about $178 billion was pushed out to health care providers in the form of Provider Relief Funding. This session will discuss the HHS Office of Inspector General’s (OIG) audit plan and processes to review provider’s use of Cares Act Provider Relief Funding (PRF), and in particular:

  • Recipient’s right to receive the PRF
  • Recipient’s compliance with the  terms and conditions applicable to PRF
  • Recipient’s compliance with mandatory reporting, and audits by the OIG
  • The legal ramifications of a negative audit finding
11:30 am-12:30 pm

5. Developments in Government Managed Care Fraud Enforcement
(not repeated)
Wayne T. Gibson
John E. Kelly
Megan Tinker

  • The trend in case rulings and the trend in enforcement actions against Medicare and Medicaid Managed Care providers and their contactors–what has changed and what is new?
  • What do smaller enforcement actions and trends suggest regarding industry oversight?
  • Are regulations changing or is enforcement increasing? Thoughts on Call Letters and other items
  • Key considerations for Health Plans, Providers, and Third Party Vendors
 

6. Grant Fraud Enforcement Trends and Compliance Best Practices
Derrick L. Franklin
Peter Taschenberger

  • Grant overview
  • The nature of fraud
  • Fraud concepts and indicators
  • Risk mitigation
  • Fraud consequences
 

7. The Pandemic is Ending: What Providers Can Expect Next
Thomas R. Barker
Kimberly Brandt

  • CMS flexibilities (1135 and regulatory flexibilities) overview
  • Supplemental funding for providers (provider relief fund and accelerated payment) overview
  • Current status of waivers, regulatory flexibilities, and supplemental funding
  • What can providers expect going forward?
12:30-1:30 pm
Lunch on your own
1:30-2:30 pm

8. Legal Ethics for Compliance Officers and In-House Counsel
(not repeated)
Charise R. Frazier
Josephine Nelson Harriott

Interactive live session in game show format that will discuss:

  • Ethical considerations for attorneys working in non-legal positions
  • Ethical obligations for in-house counsel
  • Conflicts between the role of compliance professional and counsel
  • Ethical issues in the use of technology
  • Ethical obligations when the management veers into potentially illegal conduct
 

9. Asked and Answered: OIG’s Regulatory Sprint Rule
Susan A. Edwards
Julie E. Kass
Vicki L. Robinson

  • A moderated panel with OIG senior staff
  • Answers to frequently asked stakeholder questions about new and modified safe harbors
  • Value-based arrangements, patient engagement and support, and more!
 

3. Implementing Value-Based Care: Stark
(repeat)
Troy A. Barsky
Albert W. Shay

  • Stark Law Reform: Why the changing health care industry compelled CMS to make needed reforms to this important fraud and abuse law
  • The key changes to the Stark Law’s value-based payment exceptions and the importance of understanding the scope of applicable definitions
  • Other revisions to the regulations designed to accommodate value-based arrangements
  • Practical examples of potential value-based payment arrangements and how these the revised regulations will either help or hinder innovation
  • Compliance guidance and advice for providers seeking to ensure compliance in this changing regulatory landscape
3:00-4:00 pm

10. Fraud and Compliance Considerations for Telemedicine and Digital Health: Navigating the Emerging Landscape
(not repeated)
Ty Kayam
Erica J. Kraus

  • Challenges and opportunities facing companies expanding into digital health in complying with fraud and abuse laws like the Anti-Kickback Statute and the False Claims Act
  • The expansion of digital health and partnerships between providers and digital health/technology companies, including in the areas of electronic health records, AI decision tools, telemedicine, consumer health applications, and online search and booking tools
  • The scope of the AKS, FCA, and other key laws, and the ways in which they apply to and impact technology companies entering the digital health space
  • Key guidance, enforcement actions, and litigation (including the Practice Fusion investigation and settlement, AO 19-04, OIG telehealth statements, and the new AKS rules) that are beginning to establish parameters for digital health compliance
  • Potential compliance strategies for structuring relationships, marketing, product design, and internal controls
 

4. Avoid the Long-Haul Risks of COVID Relief Funds
(repeat)
Joseph V. Geraci
​Chris Schrank

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law, making available $2.2 trillion in relief funds–of which about $178 billion was pushed out to health care providers in the form of Provider Relief Funding. This session will discuss the HHS Office of Inspector General’s (OIG) audit plan and processes to review provider’s use of Cares Act Provider Relief Funding (PRF), and in particular:

  • Recipient’s right to receive the PRF
  • Recipient’s compliance with the  terms and conditions applicable to PRF
  • Recipient’s compliance with mandatory reporting, and audits by the OIG
  • The legal ramifications of a negative audit finding
 

9. Asked and Answered: OIG’s Regulatory Sprint Rule
(repeat)
Susan A. Edwards
Julie E. Kass
Vicki L. Robinson

  • A moderated panel with OIG senior staff
  • Answers to frequently asked stakeholder questions about new and modified safe harbors
  • Value-based arrangements, patient engagement and support, and more!
4:30-5:30 pm

11. The Role of Boards of Directors and How to Interact with Them​
(not repeated)
Laura Ellis
Thomas Flynn
William T. Mathias

  • Compare and contrast the perspectives of OIG lawyer, compliance officer, and outside lawyer on the role of Boards of Directors with respect to organizational compliance and compliance programs
  • The OIG’s guidance documents on the role of Boards
  • Best practices for educating diverse Board members about relevant risks and issues
  • Practical tips for interacting with Boards 
 

7. The Pandemic is Ending: What Providers Can Expect Next
(repeat)
Thomas R. Barker
Kimberly Brandt

  • CMS flexibilities (1135 and regulatory flexibilities) overview
  • Supplemental funding for providers (provider relief fund and accelerated payment) overview
  • Current status of waivers, regulatory flexibilities, and supplemental funding
  • What can providers expect going forward?
   

 

In-Person Program Format

How It Works

  • We will offer 11 in-depth breakout sessions where speakers and attendees can interact and collaborate with each other in-person.
  • We consider the health and safety of all those onsite at in-person programs our top priority. AHLA will follow guidance and requirements issued by the CDC as well as by state and local government and are working with the hotel to ensure your health and safety as we transition back to in-person programming. 
  • All attendees, who register for the in-person component of the program, will be required to commit to our Duty of Care (see below) agreeing to follow the protocols we establish and monitor their own health for the health and safety of all. 
  • On September 30, to minimize crowding, we are offering extended time for registration. We have adopted a new onsite registration system by providing seamless, touchless check-in, onsite badge printing, and safety supplies to all attendees to use while in attendance.
  • Built-in extended time between sessions for moving from room to room, networking with colleagues, and personal breaktime.  
  • Socially distanced seating arrangements in breakout rooms, regular cleaning in and around meeting spaces, and appropriate signage/floor decals to reinforce spatial distancing and other safety reminders.

 

Virtual Program | September 21-22, 2021


Tuesday, September 21, 2021 

11:00 am-12:15 pm EDT

1. Year in Review
Robert G. Homchick
Kristen B. Rosati

As usual, this will be a fast-paced overview of key developments over the past year, including:

 The Change in Administration and Health Care Reform
 False Claims Act Developments, including Enforcement Statistics, Trends and Developments
 Stark and AKS Sprint regulations
 Public Health Highlights 
 COVID-Related Legislation, Funding, Audits and Enforcement
 Reimbursement Highlights
 HIPAA and HIT Developments: Information blocking and interoperability, OCR enforcement and data breaches

12:30-1:30 pm  EDT

2. A Peek Behind the Curtain: The Interactions of DOJ, OIG, CMS, and the HHS Office of General Counsel
Karen S. Glassman
Eden Heard
Natalie Waites
Lisa Ohrin Wilson

  • An insider's perspective on how DOJ, OIG, CMS, and HHS Office of General Counsel (HHS OGC) interact during the course of investigations, litigation, review of self-disclosures, policy development, and other government work
  • The roles of each of the agencies in interpreting and enforcing critical fraud and abuse laws, such as the federal Anti-kickback Statute, the Physician Self-referral Law, and Medicare/Medicaid rules and regulations
  • Tips for providers during investigations, self-disclosures, and other interactions with these government departments and agencies 
 

3. Recent Developments Provider Based Billing
Jessica Matthews
 Lawrence W. Vernaglia

  • Fundamental compliance considerations associated with Medicare provider-based status
  • Survey of recent cases and settlements based on alleged provider-based deficiencies
  • Considerations and perspectives on managing potential non-compliance
 

4. Emerging HIPAA Issues and the Compliance Challenges they Present
 Camella Boateng
Anthony J. Burba
Serena E. Mosley-Day

  • OCR compliance and enforcement update
  • Recent criminal HIPAA enforcement
  • Day-to-day compliance challenges
  • What to do and what to be thinking when there’s a breach
    • Cybersecurity and Ransomware
1:45-2:45 pm EDT

5. Measuring the Effectiveness of Your Compliance Program: Evaluation of Corporate Compliance Programs
 Lisa Adkins
Laura Ellis
Joseph F. Zielinski

  • How to measure your Program's effectiveness using the Department of Justice Evaluation of Corporate Compliance Programs
  • The three "fundamental questions" that pursuant to Department of Justice Evaluation of Corporate Compliance Programs should be asked to determine the effectiveness of a compliance program
  • Apply and reference other compliance guidance issued by the Office of Inspector General to the Department of Justice’s three "fundamental questions"
  • Assess the effectiveness of a compliance program using the DOJ’s Evaluation of Corporate Compliance Programs, which specifically calls out various elements associated with a compliance program and what questions to ask to assess those elements
  • Ask questions about, receive, and see demonstrated a tool that they can use to apply a data driven approach to assess how effective their Compliance Program is using the DOJ Evaluation of Corporate Compliance Programs and other compliance guidance issued by OIG
 

6. Sub-regulatory Guidance in Fraud and Compliance Actions
Lynn M. Adam
 Daniel J. Hettich

In Azar v. Allina Health Services the Supreme Court held that the Medicare statute, in contrast to the APA, required CMS to adopt even “interpretative” rules and policies through notice and comment rulemaking if those rules have a substantive legal effect on reimbursement. This year, HHS finalized new Good Guidance regulations and established a Guidance Repository. We address questions regarding how CMS’s extensive sub-regulatory guidance, encompassed in hundreds of pages of manuals and other sources, should be viewed in FCA and compliance actions. This session will discuss:

  • What is a “guidance document” under HHS’s new regulations?
  • When, if ever, does “sub-regulatory” guidance create a substantive legal standard under Allina
  • The role of sub-regulatory guidance in FCA cases
  • The role of sub-regulatory guidance in assessing compliance and self-reporting issues
  • How do local coverage determinations (LCDs) and Advisory Opinions fit in
 

7. Clinical Laboratory Regulatory and Enforcement Update for 2021
Joyce E. Gresko
Danielle M. Sloane
Andrea Treese Berlin​

COVID-19 highlighted the important role of clinical laboratories in the health care system, prompting an explosion of development and new entrants–big and small–into the market. This presentation will focus on the many compliance and regulatory issues that are particular to clinical labs and inform participants about:

  • Significant regulatory developments affecting laboratories, including oversight of laboratory-developed tests, the “information blocking” rule and release of test reports, and compliance with Medicare’s COVID testing “turn-around time” billing rule
  • How amendments to Stark Law and Anti-Kickback Statute regulations affect arrangements between laboratories and physicians/other health care entities, and the kinds of flexibilities the changes provide
  • Approaches to laboratory compliance with the all-payor “Eliminating Kickbacks in Recovery Act” (EKRA)
  • What is new with requirements for documentation to support the medical necessity of laboratory tests
  • Enforcement and program integrity efforts related to COVID and other laboratory testing, including an overview of the most significant recent laboratory cases and settlements and what we can learn from them about government enforcement priorities 
3:00-4:30 pm EDT

8. Billing and Coding Bootcamp
Michael D. Miscoe
Robert A. Pelaia
Leonta (Lee) Williams

 The basics of procedural (CPT) and diagnosis (ICD-10) coding
 General guidance on use of the CPT and ICD-10 coding manuals
 Common issues associated with coding billing disputes
 Common legal/compliance issues based on coding
 The basics of inpatient procedural coding (ICD-10-PCS)
 The importance of internal facility guidelines

 


Wednesday, September 22, 2021 

11:30 am-12:00 noon EDT

9. Keynote Address
Christi A. Grimm

  • Principal Deputy Inspector General Grimm will announce details for a new initiative to modernize OIG guidance, the advisory opinion process, and its publicly available information
  • She will also provide updates on priority areas for OIG oversight and enforcement
12:15-1:15 pm EDT

10. Demystifying the Stark Law’s Overhauled “Big 3”: Commercial Reasonableness, the Volume or Value Standard and FMV
 Leia C. Olsen
Joseph N. Wolfe

Insight into the Big 3 and how the new guidance will impact health care contracting, compliance strategies, and future enforcement priorities, including the following: 

  • The reorganized FMV standard and important examples from the commentary
  • The new commercial reasonableness definition and clarifications from CMS regarding losses
  • The objective volume/value test and new guidance on directed referrals
  • The potential impact on physician arrangements, compliance strategies and enforcement
 

11. Conducting Effective Internal Investigations: Avoiding Potential Pitfalls and Ensuring Diversity
  Scott R. Grubman
Mina Rhee
D'Andrea J. Morning

  • Effective strategies in conducting internal investigations and how to avoid common pitfalls
  • Conducting an internal investigation during the course of a parallel government investigation and how to avoid common issues such as waiver of privilege
  • Ethical and legal dilemmas facing lawyers conducting internal investigations and how to navigate them
  • Considerations for the appropriate venue for internal investigation interviews (are virtual interviews appropriate?)
  • Making the case for diversity on the internal investigation team
 

12. Emerging Trends in Health Care Technology and Cybersecurity Enforcement: What You Need To Know
R. Joey Burby
Bethany L. Rupert
Lauren Lively

  • The latest developments in health care technology, including new software for electronic health records, information blocking, and integration of new technology into the health care process
  • With new developments in technology comes the potential for new focus areas for federal enforcement.  We’ll discuss some of the latest health fraud matters out of DOJ involving health technology, as well as where enforcement focus areas may develop
  • An assessment of cyber security and data privacy risks for health care organizations, such as a data breach involving HIPAA-protected information or a ransomware attack.  We’ll discuss the latest considerations with these risks and make suggestions regarding how to protect against such risks
  • How cyber security risks are becoming a focal point for government contracts, which could lead to further FCA enforcement with regard to express or implied certification of certain cyber standards
1:15-1:30 pm EDT
Visit the Sponsors
1:30-2:30 pm EDT

13. The Patient Engagement and Support Safe Harbor: A New Opportunity to Address Social Determinants of Health
 Timothy P. Blanchard
Benjamin Wallfisch

  • The patient engagement and support safe harbor: What it is and what it isn’t
  • The prerequisite value-based framework: Not as onerous as you might think
  • Safe harbor requirements and limitations
    • Limitations on protected remuneration
    • Requirements for protected tools/supports
  • Considering the safe harbor in several scenarios
 

14. Digging Deeper in Your Audits: An Investigative Approach to Effective Compliance, the 60-Day Rule, and Identifying Overpayments
 Lori Laubach
Kelly Wittmeyer

  • Brief overview of audit and monitoring
  • Knowing when to audit and how to structure the audit, getting it done, and reporting
  • Reporting and returning overpayments
  • Thoughts about compliance obligations and maximizing protections
 

15. False Claims Act Update
Kirk Ogrosky
Benjamin C. Wei

  • Recent key FCA cases and what they portend for future litigation
  • What qualifies as a "public disclosure" to bar relators from litigating FCA claims. The world of internet publication and defining "news media." US ex rel. Integra Med Analytics LLC v. Providence Health & Services, No. 16-1694, 2019 WL 3282619 (C.D. Cal. July 16, 2019)
  • Does the FCA require an "objective" scienter standard or can a defendant who acted under an incorrect interpretation of a statute or regulation act with the requisite knowledge? US ex rel. Schutte v. SuperValu, Inc., No. 20-2241 (7th Cir. Aug. 12, 2021)
  • What are genuine materiality issues for trial after 11th Circuit rules the relevance of continued payment by the government may "vary depending on the circumstances." US ex. rel. Bibby v. Mortgage Investors Corp., No. 19-12736, 2021 WL 137739 (11th Cir. Jan. 15, 2021)
2:45-3:45 pm EDT

16. Private Equity in Physician Practices: Compliance Considerations
Annapoorani Bhat
Kelly Koeninger

Private equity (PE) involvement in the health care sector has continued to grow, and physician practices in diverse sub specialties are experiencing the benefits and complications of alliances with PE.  With PE-backed health care companies continuing to see scrutiny from federal and state regulators for failure to appropriately comply with health care regulatory laws, it is important for PE firms and their partners to understand the complex regulatory environment they operate in and to structure arrangements to ensure compliance. This will be an intermediate session for in-house and outside counsel and compliance officers. The session will provide:

  • Recent settlements entered into by private-equity backed companies
  • Key points of enforcement focus in settlements
  • Various structures utilized by private equity firms when investing in physician practices
  • How health care fraud and abuse laws intersect with structuring private equity partnerships, with a particular focus on key areas of enforcement focus
  • Valuation concerns, and ways in which these agreements can be structured within fair market value
  • How to structure compliant arrangements, with case studies
  • Case studies based on real life experience with an illustration of types of arrangements and fair market value checklist
 

17. EKRA: Enforcement Trends and Future Projections
Jacob T. Elberg
Jim Hayes
Laura F. Laemmle-Weidenfeld

  • Cases that have charged EKRA to date
  • The conduct underpinning recent charges
  • Upcoming trials and charges
  • The various roles of the various DOJ components and other government partners in EKRA enforcement  
  • Counseling health care providers on key EKRA risk areas
 

18. Health Care Fraud Enforcement: Does COVID-19 Represent a Changed Risk Environment?
Patrick S. Coffey
Ahmed A. Elganzouri
Linda A. Wawzenski

  • Recent False Claims Act cases and the enforcement initiatives aimed at health care providers
  • The COVID-19 impact on enforcement: Is there a new or different focus?
  • Current DOJ priorities: Early returns and predictions under the new administration
  • Issues on whistleblower cases, including DOJ dismissals and potential changes to the FCA
  • What recent settlements suggest as key concerns for hospitals and systems
  • The latest on effective compliance and key issues for providers in the aftermath of the pandemic


On Demand Offerings


On Demand (Available Friday, September 17) 

I. Fundamentals of the Anti-Kickback Statute, the Beneficiary Inducements CMP, and the Physician Self-Referral Law​
Samantha C. Flanzer
Julia C. Reiland
Lisa Ohrin Wilson

 High level introduction to the nuts and bolts of the Federal Anti-Kickback statute (AKS), beneficiary inducement provisions of the CMP, and the Physician Self-Referral Law (PSL)
 Relationship between the AKS, the PSL, and the False Claims Act
 Practical tips for analyzing financial arrangements for compliance with the Federal fraud and abuse laws

II. Administrative Enforcement: Case Study with Perspectives from CMS and OIG
   Julie Burns
Kirk Sripinyo
Judith A. Waltz

 New authorities and focus for COVID-19 Fraud
 CMS–Revocations of Enrollment, including under the “Affiliates” Rule, and Collateral Consequences
 OIG–CMP Authorities, Exclusion, and the Role of the Fraud Risk Indicator
 Appeals

III. A Primer on DOJ’s Main Civil Enforcement Tool: The False Claims Act
Demme Doufekias
Michael E. Shaheen

 The elements of a False Claims Act violation
 The consequences of a False Claims Act violation
 What governmental agencies are involved in False Claims Act investigations
 How the government investigates allegations of False Claims Act Violations
 Industries most susceptible to False Claims Act activity and scrutiny by the government
 False Claims Act trends, including recovery statistics and new matter statistics

IV. Privacy and Security Nuts and Bolts
Serena E. Mosley-Day
Iliana L. Peters

 Who are covered entities and business associates under HIPAA
 The Privacy, Security, and Breach Notification Rules
 The Privacy Rule’s limits on uses and disclosures, individual privacy rights, and administrative requirements
 The Security Rule’s requirements for administrative, physical, and technical safeguards
 The Breach Notification Rule
 HIPAA and COVID-19
 HIPAA policy updates and recent enforcement actions

V. Legal Ethics Considerations of Conducting Privileged, Crisis-Response Investigations of Health Care-Related Cyberattacks (Session was Pre-Recorded for the Annual Meeting, June 2021)
Dawn R. Crumel
Todd Presnell

It’s no secret that perpetrators of ransomware, malware, and a myriad of other cyberattacks increasingly target health care providers, payors, and others warehousing confidential and protected patient information. How the corporate victims immediately respond to these crises presents a variety of potential adverse consequences, including creating evidence that may become discoverable in the inevitable third-party actions and government inquiries. In this presentation, the speakers will discuss:

 Establishing and maintaining privilege and work-product protections
 Practical tips for avoiding a second liability from the cyberattack
 Best practices for conducting an investigation with forensic and other experts

VI. Social Determinants of Health and COVID-19: What is the Fraud and Abuse Landscape Now? (Session was Pre-Recorded for the Physicians and Hospitals Law Institute, February 2021)
Tony R. Maida
Vicki L. Robinson

 How social determinants impact value-based health care in the current pandemic environment
 The new final changes to the anti-kickback statute (AKS) and beneficiary inducement statute (BIS) regulations regarding patient incentive arrangements
 Apply the regulations, OIG guidance, and COVID-19 waivers to various patient incentive arrangements, including co-pay waivers, local transportation, items of nominal value, promoting access to care, and more


This program will be formatted as a two-day virtual program with an in-person add on for those ready to connect in person with additional breakout sessions and a networking event.

Virtual Program Format

How It Works

  • Once you register, you'll begin to receive information to prepare for the live virtual event. 
  • Prior to the live event, participants will receive an email with instructions on how to log in on the day the program starts. You will also receive a link to the full set of program materials. 
  • We are currently working on the program schedule. During some time slots, participants will decide between 2-3 live sessions. Watching sessions live will give you the opportunity to be an active participant in live question and answer portion of the presentations. Get your questions answered, chat, and collaborate with other participants and speakers.
  • Miss any sessions? No problem, you can watch them on demand later.
  • Participants will be able earn continuing education credits for, not only the live sessions attended, but for any on-demand sessions.  

Benefits of the Virtual Program

  • Speakers are pre-recorded so speakers can participate in the text chat during the session, driving conversation forward and allowing for speakers to answer questions and clarify points throughout their session.
  • Access to all the sessions on demand for viewing later on your own time, with continuing education credits available for both live and on demand.
Program Accessibility and Special Needs

Click here for more information regarding accessiblitiy accommodations for our in-person programs.

Thank You to Our Fraud and Compliance Forum Sponsors

Platinum Level Sponsor

Gold Level Sponsor

Silver Level Sponsors

Bronze Level Sponsors

If your organization is interested in sponsoring AHLA's Fraud and Compliance Forum, please contact Valerie Eshleman.