Health Services


Home Health Care Continued to Be a Federal Enforcement Target in 2025
November 18, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

The 2025 National Health Care Fraud Takedown, announced in June, was the largest in history, with 325 defendants charged (including 96 providers) in 50 federal districts. In all, the charged schemes involved more than $14 billion in intended loss, and more than $245 million in cash, luxury vehicles, cryptocurrency and other assets were seized. These

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The Intersection Between OMIG’s Home Care Audit Protocols and Liability Risk Under The False Claims Act
October 9, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

OMIG publishes audit protocols to “assist the Medicaid provider community in developing programs to evaluate compliance with Medicaid requirements under federal and state statutory and regulatory law.”[1]  Such protocols are “applied to a specific provider type or category of service in the course of an audit and involve OMIG’s application of articulated Medicaid agency policy

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The Feds Have Home Care Kickback Arrangements in Their Crosshairs
August 8, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

The federal government has demonstrated that it is more than willing to use the United States criminal code to prosecute home care agencies that pay unlawful financial inducements to generate referrals in violation of the Anti-Kickback Statute (AKS).

In a superseding indictment unsealed in March 2025, the United States Attorney’s Office for the Eastern District

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COVID-19 Pandemic Fraud Enforcement Efforts Overview
May 23, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

Jeff Kaiser’s article, “COVID-19 Pandemic Fraud Enforcement Efforts Overview,” was published on the Lexis Nexis legal research tool, Practical Guidance.

In the article, Jeff offers a comprehensive overview of enforcement efforts related to COVID-19 pandemic fraud.

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NYS DOH Releases New Electronic Material Transaction Form
May 21, 2025 | Norton L. Travis | Jeffrey Ehrhardt | Emily E. Manning | Corporate | Health Services

Just last week, we reported that the 2025/26 NYS Budget Bill did not include a provision that would have increased the requirements for seeking Department of Health (DOH) approval of a material healthcare transaction (which generally means one that increases revenues from healthcare services by at least $25 million) [here]. We have previously written about

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Expanded Healthcare Transaction Notice/Review Dropped from Final 2025/26 NYS Budget Bill
May 16, 2025 | Norton L. Travis | Jeffrey Ehrhardt | Corporate | Health Services

We recently wrote about proposed legislation that would have substantially increased the existing reporting requirements for material healthcare transactions in NYS that have existed since Public Health Law (PHL) Article 45-A was enacted two years ago. We provided a detailed review of the current PHL 45-A here and here.

The proposed legislation would have amended PHL 45-A and

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It’s More Than Just the Money
April 15, 2025 | Norton L. Travis | Corporate | Health Services | Dental Practice Counseling
The importance of analyzing both economic and noneconomic key issues for a successful health care transaction

With lowering interest rates and federal deregulation, 2025 promises to be a robust comeback year for health care mergers and acquisitions (M&A). At the same time, we’re likely to see more conservative pricing, especially as private equity investors

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Quality of Care Considerations in OIG’s Nursing Facility Compliance Guidance
March 25, 2025 | John F. Queenan | Jeffrey Ehrhardt | Compliance, Investigations & White Collar | Health Services

John Queenan, Mary Aperance and Jeff Ehrhardt wrote, “Quality of Care Considerations in OIG’s nursing Facility Compliance Guidance,” for the spring 2025 issue of USLAW Magazine.

The article details the Industry Segment-Specific Compliance Program Guidance for Nursing Facilities (ICPG) and how the guidance may be used as a basis for investigations and enforcement actions.

To read

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Federal Agencies Express Concerns About Health Care Market Consolidation and Role of Private Equity
January 23, 2025 | Health Services

On January 15, 2025, the Federal Trade Commission (FTC), Department of Justice (DOJ), and Department of Health and Human Services (HHS) released a joint report continuing their collaborative initiative to address consolidation within the health care sector. This initiative, launched in December 2023, aims to enhance competition and better regulate private equity investments within the

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$68 Million CDPAP Fraud Indictment Unsealed Amidst Industry Changes
October 29, 2024 | Jeffrey Ehrhardt | Compliance, Investigations & White Collar | Health Services

On October 9, 2024, the United States Attorney’s office in the Eastern District of New York unsealed an indictment alleging that eight defendants defrauded Medicaid of approximately $68 million.[1] The alleged scheme involved two adult day care programs and a home care financial intermediary, all owned and controlled by the same individuals, as well as

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