How To Respond to A FINRA or SEC Wells Notice

On July 20, 2022, the US Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert (Alert) concerning the fraud and abuse risks associated with healthcare practitioners entering into arrangements with telemedicine companies. The Alert follows dozens of civil and criminal investigations into alleged fraud schemes involving companies that claimed to provide telehealth, telemedicine or telemarketing services but allegedly engaged in kickbacks and substandard medical practices to generate medically unnecessary orders and prescriptions for items or services, resulting in submissions of fraudulent claims to Medicare, Medicaid and other federal healthcare programs.

The Alert also comes on the heels of a nationally coordinated US Department of Justice (DOJ) takedown involving more than $1 billion in allegedly fraudulent telemedicine schemes. The Alert identifies seven characteristics which could suggest a telemedicine arrangement presents potential risk for fraud and abuse. While the characteristics highlighted in the Alert are not representative of the legitimate and crucial telemedicine services offered by most healthcare providers, the Alert and the government’s sustained focus on potential telemedicine-related fraud cases provide an important opportunity for healthcare providers to evaluate their telemedicine offerings and arrangements and strengthen their telemedicine compliance activities.

Source: How To Respond to A FINRA or SEC Wells Notice / The National Law Review

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