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Fraud and Compliance Forum

Schedule

This two-day conference will be held in-person and virtually. We are excited for attendees to connect and network in person, but for those who are unable to join us in DC, you will be able to tune in virtually. Whether you're attending on-site or online, you'll enjoy interactive sessions, expert insights, and real-time engagement designed to educate from anywhere. All sessions are recorded and will be available to both the in-person and virtual audiences following the conference. The full agenda will be available soon.

Monday, September 21, 2026 (all times are EDT)

10:30 AM - 1:30 PM

Virtual Pre-Conference Sessions

10:30 AM - 12:00 PM

Anti-Kickback, Physician Self-Referral (Stark) and CMP Bootcamp (Introductory) VIRTUAL

Kristin C. Carter, Johns Hopkins Health System
Tiana Korley, Senior Counsel, DHHS Office of the Inspector General

12:15 - 1:30 PM

What Every Health Care Lawyer Should Know About Coding: A Practical Bootcamp (Introductory) VIRTUAL

Robert A. Pelaia
Lenota Williams, Senior Director of Education, American Academy of Professional Coders

Tuesday, September 22, 2026

5:00 - 6:30 PM

In-Person Conference Attendee Assistance: Check-In and Badge Pick-Up

Come early to the AHLA Registration area to print out your badge.

5:30 - 6:30 PM

Welcome Reception

This event is included in the conference registration. Attendees, speakers, and registered guests are welcome. Interested in sponsoring this event? Sponsor.

Wednesday, September 23, 2026

7:00 AM - 5:15 PM

Conference Attendee Assistance: Check-In and Badge Pick-Up

7:00 - 8:00 AM

Conference Breakfast

This event is included in the conference registration fee. Attendees, speakers, and registered guests are welcome. Interested in sponsoring this event? Sponsor.

8:00 - 10:30 AM

General Session

8:00 - 8:15 AM

Welcome and Patricia Meador Award Recognition

Christine L. White, AHLA President, Westchester Medical Center
Tony Maida, Planning Committee Chair, McDermott Will & Schulte

8:15 - 9:30 AM

1. Year In Review IN-PERSONSTREAMING

9:45 - 10:30 AM

2. Keynote Address IN-PERSONSTREAMING

10:45 AM - 12:00 PM

3. An APP for That? Solving Compliance Challenges to Optimize Advanced Practice Provider Utilization (not repeated) IN-PERSONSTREAMING

Michelle Berholz Frazier
Stacy Gerber Ward, von Briesen & Roper
Milada Goturi, Thompson Coburn LLP

The integration of Advanced Practice Providers (APPs) into health care delivery models has expanded rapidly, offering increased access and efficiency, while also creating compliance pitfalls in documentation, supervision, and billing practices. This session will discuss:
  • Legal and operational considerations for efficient utilization of APPs by hospitals and physician practices, including, scope of practice, physician supervision and institutional policy requirements
  • Key compliance requirements for split/shared and incident-to billing, including recent regulatory updates
  • Fraud and abuse considerations, enforcement trends and recent DOJ settlements involving APP-related billing practices and financial arrangements
  • Actionable guidance to help organizations mitigate risk while effectively integrating APPs into care delivery models

4. Big Data, Big Consequences: Enforcement and the Integration of Data Analytics and AI IN-PERSONSTREAMING

Anna Ferreira-Pandolfi, US Department of Health and Human Services, Office of Inspector General, Special Agent/Criminal Investigator FBI
Albert Tenuta, Special Agent, Federal Bureau of Investigation
Denae Thomas, Paul Hastings
Torrey Young, "Seyfarth Shaw LLP

  • Current enforcement priorities based on the OIG Work Plan
  • Data Fusion Center, including what data goes into the Data Fusion Center
  • How AI is being used to both enforce and perpetuate fraud
  • What providers can be doing proactively to mitigate risks associated with data patterns

5. To Disclose, or Not to Disclose, That is the Question IN-PERSON

Lisa Adkins, SVP and Chief Compliance Officer, University of Maryland Medical System
John E. Kelly, Barnes & Thornburg LLP
Leia C. Olsen, Lead System Compliance and Investigations Counsel, Ascension

This panel will provide their unique perspectives and discuss:
  • How the general enforcement landscape encourages self-disclosure
  • Self-disclosure options offered by DOJ and HHS-OIG as well as key requirements
  • What it means to conduct a sufficient internal investigation to fully identify the issue and remedial steps.
  • Key considerations when deciding where to self-disclose (which agency) and risks of not self-disclosing
  • The impact of self-disclosure on an organization, and how cooperation fits into the decision
12:00 - 1:15 PM

Lunch and Learn, sponsored by Forvis Mazars PRE-REGISTRATION REQUIRED

There is no additional fee; space is limited; pre-registration required. Continuing Education Credits are not available for the lunch.

1:30 - 2:30 PM

6. The Algorithm as Accomplice: AI-Driven Documentation, Coding, and the Emerging FCA Risk Landscape (not repeated) IN-PERSONSTREAMING

Robert DeConti, King & Spalding
Hoyt Sze, Sheppard Mullin Richter & Hampton LLP
Donald Yoo, Chief Compliance Officer, UCLA Health Los Angeles

AI tools are reshaping how providers document care, code encounters, and submit claims—and regulators are paying close attention. This session takes a practical look at the fraud and abuse risks that come with AI-assisted workflows, from ambient scribes to coding nudges embedded in EHR systems to AI-driven risk adjustment tools. With the DOJ and HHS flagging AI-enabled EHR manipulation as a top enforcement priority and a new Health Care Fraud Data Fusion Center using AI to detect fraud schemes and the recent implementation of, the same technology transforming care delivery is also transforming enforcement. Presenters will draw on real enforcement actions and on-the-ground compliance experience at a large health system to help attendees understand where the risk actually lives—and what to do about it.
  • AI-driven workflows—ambient scribes, retrospective chart reviews, risk adjustment coding tools—are drawing the most regulatory scrutiny and why
  • What the government expects providers to consider when adopting AI coding solutions based on CMS pronouncements such as the Request for Information Related to Comprehensive Regulations to Uncover Suspicious health care (CRUSH)
  • How FCA and AKS exposure can arise from AI-assisted documentation and coding, even absent any intent to defraud
  • Practical and proactive guidance on vendor oversight, human-in-the-loop safeguards, audit protocols, and governance best practices for AI-enabled clinical workflows

7. From Benchmarks and Process to Bombshell: When Physician and Advanced Practice Provider Pay Triggers Enforcement (not repeated) IN-PERSONSTREAMING

Kathryn Taylor, ECG Management Consultants
Bruce Toppin, Chief Legal Officer, Secretary & Privacy Officer, North Mississippi Health Services
Joseph N. Wolfe, Hall Render Killian Heath & Lyman PC

  • How DOJ, OIG, and relators actually use FMV analyses in investigations and how they fit in the defense
  • What recent qui tam cases, self-disclosures and government guidance reveal about potential areas of risk
  • Practical steps compliance teams can take before they receive a Civil Investigative Demand
  • Where technically “market-based” compensation still creates Stark and AKS risk
  • Red flags emerging in call pay, medical directorships, and APP supervision stipends
  • How governance and documentation support defensibility
  • Documenting FMV and commercial reasonableness in challenging recruitment and retention situations

8. These Are a Few of Our Favorite Things: Underutilized Tools in CMS’s 2020 Rule Modernizing and Clarifying the Physician Self-Referral Regulations IN-PERSONSTREAMING

Christopher Janney, Dentons US LLP
Lisa O. Wilson, Senior Technical Advisor, Centers for Medicare and Medicaid Services

In 2020, CMS finalized its rule for “Modernizing and Clarifying the Physician Self-Referral Regulations” (MCR). Among the agency’s objectives was to reduce the regulatory impact and burden of the self-referral law by creating new exceptions and revising, interpreting, and clarifying existing exceptions and special rules. Over the past five years, DHS entities and physicians have used many of these tools to improve compliance with the self-referral law and avoid unnecessary disclosures under the Self-Referral Disclosure Protocol (SRDP). At the same time, both CMS (in reviewing SRDP submissions) and regulatory counsel (in working with DHS entities and physicians) have observed that a number of MCR tools remain misunderstood or otherwise underutilized. This presentation will explore several of these tools, including those relating to:
  • Value-based arrangements
  • Reconciling payment discrepancies
  • Amendments to existing arrangements
  • Limited remuneration to a physician

9. Cyber-Fraud Is Health Care Fraud IN-PERSON

Renée Brooker, Qui Tam & Whistleblower Attorney, Tycko & Zavareei LLP
Michael A. Hoffman, Senior Trial Counsel, US Department of Justice–Civil Division, Commercial Litigation Branch, Fraud Section
Sara McLean, Akin Gump Strauss Hauer & Feld LLP

2:30 - 2:45 PM

Coffee and Networking Break, sponsored by Latham & Watkins

2:45 - 3:45 PM

10. How Safe (Harbored) are Discounts?(not repeated) IN-PERSONSTREAMING

William T. Mathias, Bass, Berry & Sims PLC
Heather Westphal, Senior Counsel. US Department of Health and Human Services, Office of Inspector General

On the surface, the concepts behind the Discount Exception and Safe Harbor seems pretty simple. The government wants to encourage price competition and to make sure that it is getting the benefit of such competition. However, as you peel back the layers, there are differences between the Discount Exception and the Discount Safe Harbor. In the last year, the OIG has issued two advisory opinions that have shed light on how the OIG analyzes discounts. This session will discuss:
  • The scope and differences between the Discount Exception and Safe Harbor
  • How the federal courts have approached discounts
  • What we can learn from recent discount advisory opinions (25-11 and 26-03)
  • Utilize hypotheticals to tease out the risks posed by discounts

11. Rise of the Machines: Managing Risk in the Implementation of Technology in Health Care IN-PERSONSTREAMING

Anthony J. Burba, Barnes & Thornburg
Ted Lotchin, Chief Compliance Officer, UNC Health
Ross Whitehurst, Associate General Counsel, UHS, Inc.

With the proliferation of AI tools, telehealth programs, and other disruptive technologies, change in the health care industry is driving new and rapidly evolving fraud and compliance risks for organizations to manage. While these new tools present the opportunity to improve patient care and organizational efficiencies, they also bring unique regulatory risks and challenges ranging from their impact on clinical decision making to ensuring the proper protection of patient privacy. Accordingly, responsible governance of AI implementation and the growth of virtual health care is more important than ever. This panel will center around the real-world fraud and abuse risks created by these new technologies and real-world best practices for health care organizations to build the robust compliance infrastructure and strategies required to mitigate those risks without interfering with broader enterprise benefits.
  • Most common use cases and opportunities for AI and telehealth technologies in the health care industry
  • Recent federal guidance and state law regulation of AI
  • Recent enforcement trends around technology in health care
  • What health care providers and companies are doing in the real world, in real time to address the compliance risks and potential for fraud, waste and abuse

12. Legal Ethics: Is There an Attorney in the Room? Defenses Based on Advice or Presence of Counsel IN-PERSONSTREAMING

Adrienne Frazior, Polsinelli
Jody Rudman, Husch Blackwell

  • A practical look at the emerging “Attorney in the Room” defense as recognized by the First Circuit in United States v. SpineFrontier, Inc.
  • In a highly regulated area, health care providers often seek counsel before entering into high stakes transactions, business arrangements, and taking positions in response to inquiries, audits and investigations
  • The traditional advice of counsel defense, waiver of privilege, and mechanics
  • The SpineFrontier “attorney in the room” defense and provides practical insight for invoking this defense and arguing it
  • Factors for determining waiver of the attorney-client privilege, protecting the privilege while usefully invoking the defense, and the impact of presenting the defense
  • Nuances such as documenting the advice, differentiating business advice from legal advice, and what might happen when co-defendants adopt inconsistent positions

13. From “Pay and Chase” to “Detect and Deploy”: CMS Anti-Fraud Initiatives, Regulatory Authorities, and Actionable Items for Stakeholders IN-PERSON

Thomas Kessler, Kessler Healthcare Consulting, LLC
Jonathan York, Morgan Lewis & Bockius LLP

  • CMS’s proactive enforcement model (“detect-and-deploy”): We begin with a broad overview of CMS’s current model, what it is, how it differs from traditional “pay-and-chase,” and why it impacts day-to-day compliance governance (including increased reliance on advanced analytics/AI and automated checks)
  • Overview of CMS’s Regulatory Authorities to “Detect and Deploy” antifraud initiatives
    • Original purpose and recent changes to Medicare Provider Payment Suspension process
    • Original purpose and basis for CMS enrollment and billing privileges revocations
  • CMS’ utilization of expanded/underused authorities: An exploration of CMS’s recent deployment of suspensions and revocations and consequences for providers, systems, and suppliers, we’ll move into an overview of what the industry is seeing with respect to CMS’s use of certain authorities to quickly cut off funding to providers/suppliers
    • Overview of “affiliations” rule and relationship to CMS’s revocation authority
    • Potential regulatory changes to the Medicare Provider Payment Suspension process
    • Use of the Fraud Prevention System Fraud Alerts and Unified Program Integrity Contractor Investigations
  • CMS Current Industries and Issues: We will look at healthcare subindustries like hospice and how CMS is deploying its anti-fraud initiatives and how it will affect providers, systems, and suppliers. We will look to the practical implications of how CMS’s “proactive” approach is operating on the ground. For hospice, specifically, this will include explanation of PPEO review and CMS and its Medicare Administrative Contractors’ (MACs’) use of the “affiliations” rule to revoke billing privileges
  • Practical implications and responses for stakeholders: Finally, the presentation will end with an overview of the appeals process, and the pitfalls providers/suppliers can avoid. We highlight operational investments stakeholders can take in order to stay ahead of CMS
4:00 - 5:15 PM

14. Everything You Ever Wanted to Know about Beneficiary Inducements (but were too afraid to ask) (not repeated) IN-PERSONSTREAMING

Stewart Kameen, Bass Berry & Sims
Julie Taitsman, BDO USA Consulting
Benjamin Wallfisch, Polsinelli

Former OIG attorneys talk through what the health care industry can give to patients, what the relevant legal constraints are, and some common pitfalls and misconceptions. The discussion also will highlight new and evolving authorities relevant to beneficiary inducements and patient assistance, including recent advisory opinions and case law. Topics to address include:
  • What can providers and manufacturers give to patients, and what are the limitations?
  • What are the rules around cost-sharing waivers, free transportation, nominal gifts, and other perks offered to patients?
  • When and how can industry-funded charitable foundations provide patient support?
  • What are the differences between the Beneficiary Inducement CMP and the Anti-Kickback Statute (and why does it matter)?

15. When Compliance Fails: How Good Programs Lead to Fraud Liability—and How to Fix Them IN-PERSONSTREAMING

Tony Maida, McDermott Will & Schulte
Lisa Re, Arnold & Porter

  • Recurring compliance breakdowns that have led to fraud and abuse liability in enforcement actions, including gaps in auditing, escalation, and oversight
  • How well-intentioned compliance programs fall short in practice, with a focus on structural weaknesses, cultural barriers, and failure to operationalize policies
  • Recent enforcement trends and case examples to illustrate how regulators evaluate compliance effectiveness and assign liability
  • Practical, actionable strategies to strengthen compliance programs, mitigate risk, and better align day-to-day operations with regulatory expectations

16. Is Every Case a Part C Case Now? Why the Newest Waves of Medicare Advantage Enforcement Need to Be on Everyone's Radars IN-PERSONSTREAMING

Erica Blachman Hitchings, Whistleblower Law Collaborative LLC
Amy Hargreaves, Latham & Watkins LLP
Sarah Kessler, Deputy Branch Chief, Administrative and Civil Remedies Branch, HHS-OIG Office of Counsel to the Inspector General
Katherine McGrath, Sheppard Mullin Richter & Hampton LLP

5. To Disclose, or Not to Disclose, That is the Question (repeat) IN-PERSON

Lisa Adkins, SVP and Chief Compliance Officer, University of Maryland Medical System
John E. Kelly, Barnes & Thornburg LLP
Leia C. Olsen, Lead System Compliance and Investigations Counsel, Ascension

This panel will provide their unique perspectives and discuss:
  • How the general enforcement landscape encourages self-disclosure
  • Self-disclosure options offered by DOJ and HHS-OIG as well as key requirements
  • What it means to conduct a sufficient internal investigation to fully identify the issue and remedial steps.
  • Key considerations when deciding where to self-disclose (which agency) and risks of not self-disclosing
  • The impact of self-disclosure on an organization, and how cooperation fits into the decision
5:15 - 6:15 PM

Networking Reception

This event is included in the conference registration. Attendees, speakers, and registered guests are welcome. Interested in sponsoring this event? Sponsor.

Thursday, September 24, 2026

7:00 AM - 12:00 PM

In-Person Conference Attendee Assistance

7:00 - 8:00 AM

Conference Breakfast

This event is included in the conference registration fee. Attendees, speakers, and registered guests are welcome. Interested in sponsoring this event? Sponsor.

8:00 - 9:15 AM

17. Medicaid Fraud Enforcement Update: Current Trends and Concerns (not repeated) IN-PERSONSTREAMING

Lori Baker, Windham Brannon
Jack Wenik, Epstein Becker & Green PC
Zada Wong, Hancock Daniel

  • Beneficiary fraud developments such as "work for Medicaid" set forth in the "Big Beautiful Bill"
  • New efforts to trim Medicaid rolls by regulatory authorities
  • Areas of focus by MFCU's and federal authorities for fraud and abuse enforcement in Medicaid
  • Strategies for avoiding enforcement actions and scrutiny
  • Current Medicaid enforcement trends and the operational risks that can lead to audits, investigations, and repayment exposure
  • How documentation, billing, credentialing, and timekeeping practices can create compliance vulnerabilities and attract regulatory scrutiny
  • Practical approaches to assessing internal controls, uncovering risk areas, and helping clients respond effectively to Medicaid audits and investigations

4. Big Data, Big Consequences: Enforcement and the Integration of Data Analytics and AI (repeat) IN-PERSONSTREAMING

Anna Ferreira-Pandolfi, US Department of Health and Human Services, Office of Inspector General, Special Agent/Criminal Investigator FBI
Albert Tenuta, Special Agent, Federal Bureau of Investigation
Denae Thomas, Paul Hastings
Torrey Young, "Seyfarth Shaw LLP

  • Current enforcement priorities based on the OIG Work Plan
  • Data Fusion Center, including what data goes into the Data Fusion Center
  • How AI is being used to both enforce and perpetuate fraud
  • What providers can be doing proactively to mitigate risks associated with data patterns

15. When Compliance Fails: How Good Programs Lead to Fraud Liability—and How to Fix Them (repeat) IN-PERSONSTREAMING

Tony Maida, McDermott Will & Schulte
Lisa Re, Arnold & Porter

  • Recurring compliance breakdowns that have led to fraud and abuse liability in enforcement actions, including gaps in auditing, escalation, and oversight
  • How well-intentioned compliance programs fall short in practice, with a focus on structural weaknesses, cultural barriers, and failure to operationalize policies
  • Recent enforcement trends and case examples to illustrate how regulators evaluate compliance effectiveness and assign liability
  • Practical, actionable strategies to strengthen compliance programs, mitigate risk, and better align day-to-day operations with regulatory expectations

16. Is Every Case a Part C Case Now? Why the Newest Waves of Medicare Advantage Enforcement Need to Be on Everyone's Radars (repeat) IN-PERSON

Erica Blachman Hitchings, Whistleblower Law Collaborative LLC
Amy Hargreaves, Latham & Watkins LLP
Sarah Kessler, Deputy Branch Chief, Administrative and Civil Remedies Branch, HHS-OIG Office of Counsel to the Inspector General
Katherine McGrath, Sheppard Mullin Richter & Hampton LLP

9:30 - 10:30 AM

18. Under the Microscope: Emerging Trends in Grant Fraud Enforcement and Research Misconduct (not repeated) IN-PERSONSTREAMING

Jessica Sarkis, Jones Day
Geeta Taylor, Senior Counsel, US Department of Health and Human Services, Office of the Inspector General

  • Recent government enforcement actions signal heightened scrutiny of federally funded research institutions and the grant lifecycle—from application to publication
  • Recent grant fraud cases and settlements that highlight the full range of enforcement tools the government may deploy—from administrative penalties under the CMPL to qui tam litigation under the FCA
  • The panel includes a former DOJ Civil Frauds attorney who helped create the DOJ's grant-fraud working group and worked on False Claims Act investigations involving research misconduct and a senior counsel for HHS OIG who has been involved in investigating research fraud cases
  • Emerging enforcement trends, the growing role of external whistleblowers in grant fraud cases, and the challenges with ascertaining the scope of damages in grant fraud FCA cases
  • The recent trend of whistleblowers who leveraged artificial intelligence tools to detect manipulated images in published scientific articles—underscoring how emerging technology is expanding the universe of potential relators and accelerating the identification of research misconduct

19. Third Party Risk Management in Retail Health Care Transactions: Practical Approaches (not repeated) IN-PERSONSTREAMING

Mark Bodner, Senior Counsel, Pharmacy and Health, Albertsons Companies, Inc.
Elysia Solomon, Outside General Counsel LLP

  • Managing third-party compliance risk in the Consumer and Retail Health space
  • Contracting strategies to consider when engaging with partners that present different risk profiles (e.g., startups vs. large tech organizations), including risk allocation and governance considerations
  • State and federal fraud, waste, and abuse (FWA) laws impacting third-party engagements, with emphasis on enforcement risk and liability exposure
  • Several high-risk areas including patient incentives, licensing requirements, audit rights, and ongoing compliance oversight obligations

20. False Claims Act Litigation Update IN-PERSONSTREAMING

Robert Salcido, Akin Gump Strauss Hauer & Feld LLP

8. These Are a Few of Our Favorite Things: Underutilized Tools in CMS’s 2020 Rule Modernizing and Clarifying the Physician Self-Referral Regulations (repeat) IN-PERSON

Christopher Janney, Dentons US LLP
Lisa O. Wilson, Senior Technical Advisor, Centers for Medicare and Medicaid Services

In 2020, CMS finalized its rule for “Modernizing and Clarifying the Physician Self-Referral Regulations” (MCR). Among the agency’s objectives was to reduce the regulatory impact and burden of the self-referral law by creating new exceptions and revising, interpreting, and clarifying existing exceptions and special rules. Over the past five years, DHS entities and physicians have used many of these tools to improve compliance with the self-referral law and avoid unnecessary disclosures under the Self-Referral Disclosure Protocol (SRDP). At the same time, both CMS (in reviewing SRDP submissions) and regulatory counsel (in working with DHS entities and physicians) have observed that a number of MCR tools remain misunderstood or otherwise underutilized. This presentation will explore several of these tools, including those relating to:
  • Value-based arrangements
  • Reconciling payment discrepancies
  • Amendments to existing arrangements
  • Limited remuneration to a physician
10:30 - 11:00 AM

Break and Hotel Checkout

11:00 AM - 12:00 PM

21. Closing the Loop: Preventing and Addressing Drug Diversion in Clinical Settings (not repeated) IN-PERSONSTREAMING

Jason Ehrlinspiel, Chief Compliance Officer, Ardent Health
Henry Leventis, Holland & Knight, LLP
Krista Tongring, President, DEA Regulatory and Compliance Practice, Guidepost Solutions

  • Applicable laws and regulations governing the acquisition, maintenance, distribution, and wasting of controlled substances in clinical settings
  • The agencies who regulate diversion issues in clinical settings
  • Recent high-profile drug diversion enforcement actions against health care facilities and providers, including criminal actions against individual providers
  • Best practices to maintain an effective drug diversion compliance program Important steps upon discovery of drug diversion in your facility

9. Cyber-Fraud Is Health Care Fraud (repeat) IN-PERSONSTREAMING

Renée Brooker, Qui Tam & Whistleblower Attorney, Tycko & Zavareei LLP
Michael A. Hoffman, enior Trial Counsel, US Department of Justice–Civil Division, Commercial Litigation Branch, Fraud Section
Sara McLean, Akin Gump Strauss Hauer & Feld LLP

12. Legal Ethics: Is There an Attorney in the Room? Defenses Based on Advice or Presence of Counsel (repeat)IN-PERSON

Adrienne Frazior, Polsinelli
Jody Rudman, Husch Blackwell

  • A practical look at the emerging “Attorney in the Room” defense as recognized by the First Circuit in United States v. SpineFrontier, Inc.
  • In a highly regulated area, health care providers often seek counsel before entering into high stakes transactions, business arrangements, and taking positions in response to inquiries, audits and investigations
  • The traditional advice of counsel defense, waiver of privilege, and mechanics
  • The SpineFrontier “attorney in the room” defense and provides practical insight for invoking this defense and arguing it
  • Factors for determining waiver of the attorney-client privilege, protecting the privilege while usefully invoking the defense, and the impact of presenting the defense
  • Nuances such as documenting the advice, differentiating business advice from legal advice, and what might happen when co-defendants adopt inconsistent positions

13. From “Pay and Chase” to “Detect and Deploy”: CMS Anti-Fraud Initiatives, Regulatory Authorities, and Actionable Items for Stakeholders (repeat) IN-PERSONSTREAMING

Thomas Kessler, Kessler Healthcare Consulting, LLC
Jonathan York, Morgan Lewis & Bockius LLP

  • CMS’s proactive enforcement model (“detect-and-deploy”): We begin with a broad overview of CMS’s current model, what it is, how it differs from traditional “pay-and-chase,” and why it impacts day-to-day compliance governance (including increased reliance on advanced analytics/AI and automated checks)
  • Overview of CMS’s Regulatory Authorities to “Detect and Deploy” antifraud initiatives
    • Original purpose and recent changes to Medicare Provider Payment Suspension process
    • Original purpose and basis for CMS enrollment and billing privileges revocations
  • CMS’ utilization of expanded/underused authorities: An exploration of CMS’s recent deployment of suspensions and revocations and consequences for providers, systems, and suppliers, we’ll move into an overview of what the industry is seeing with respect to CMS’s use of certain authorities to quickly cut off funding to providers/suppliers
    • Overview of “affiliations” rule and relationship to CMS’s revocation authority
    • Potential regulatory changes to the Medicare Provider Payment Suspension process
    • Use of the Fraud Prevention System Fraud Alerts and Unified Program Integrity Contractor Investigations
  • CMS Current Industries and Issues: We will look at healthcare subindustries like hospice and how CMS is deploying its anti-fraud initiatives and how it will affect providers, systems, and suppliers. We will look to the practical implications of how CMS’s “proactive” approach is operating on the ground. For hospice, specifically, this will include explanation of PPEO review and CMS and its Medicare Administrative Contractors’ (MACs’) use of the “affiliations” rule to revoke billing privileges
  • Practical implications and responses for stakeholders: Finally, the presentation will end with an overview of the appeals process, and the pitfalls providers/suppliers can avoid. We highlight operational investments stakeholders can take in order to stay ahead of CMS
12:00 - 1:00 PM

Lunch on Your Own

1:15 - 2:15 PM

22. Government DEI Investigations: Who's At Risk? (not repeated) IN-PERSONSTREAMING

Brandon Helms, Hall Render Killian Heath & Lyman PC
Scott McBride, Morgan Lewis & Bockius LLP

23. Innovative Health Care Technology Companies: Compliance Challenges and Managing Risk (not repeated) IN-PERSONSTREAMING

Troy Barsky, Crowell & Moring LLP
Samantha Kelen, Chief Compliance Officer, Stellar Health

  • How innovative health care technology companies serve payers and providers, including their growing role as FDRs in Medicare Advantage
  • OIG's new compliance guidance framework and its implications for technology companies: the GCPG, the Nursing Facility and Medicare Advantage ICPGs, and the January 2026 DTC platform Special Advisory Bulletin
  • Unique fraud and abuse challenges for technology-driven business models, including MAO oversight of FDRs, the DOJ-HHS False Claims Act Working Group's MA enforcement priorities, and downstream compliance obligations across the MA ICPG's key risk areas
  • Risk mitigation strategies and practical takeaways: Aligning with the GCPG's seven-element framework, assessing FDR compliance obligations, and preparing for heightened enforcement

11. Rise of the Machines: Managing Risk in the Implementation of Technology in Health Care (repeat) IN-PERSONSTREAMING

Anthony J. Burba, Barnes & Thornburg
Ted Lotchin, Chief Compliance Officer, UNC Health
Ross Whitehurst, Associate General Counsel, UHS, Inc.

With the proliferation of AI tools, telehealth programs, and other disruptive technologies, change in the health care industry is driving new and rapidly evolving fraud and compliance risks for organizations to manage. While these new tools present the opportunity to improve patient care and organizational efficiencies, they also bring unique regulatory risks and challenges ranging from their impact on clinical decision making to ensuring the proper protection of patient privacy. Accordingly, responsible governance of AI implementation and the growth of virtual health care is more important than ever. This panel will center around the real-world fraud and abuse risks created by these new technologies and real-world best practices for health care organizations to build the robust compliance infrastructure and strategies required to mitigate those risks without interfering with broader enterprise benefits.
  • Most common use cases and opportunities for AI and telehealth technologies in the health care industry
  • Recent federal guidance and state law regulation of AI
  • Recent enforcement trends around technology in health care
  • What health care providers and companies are doing in the real world, in real time to address the compliance risks and potential for fraud, waste and abuse

20. False Claims Act Litigation Update (repeat) IN-PERSON

Robert Salcido, Akin Gump Strauss Hauer & Feld LLP

2:30 - 3:30 PM

24. Closing General Session IN-PERSONSTREAMING

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See what organizations are attending the Fraud and Compliance Forum. (Available 08/23/2026)

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