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Voluntary Disclosures:
Avoid Them When Possible and How to Do Them When Necessary

Voluntary Disclosures: Avoid Them When Possible and How to Do Them When Necessary


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David M. Glaser

Compliance efforts invariably uncover situations where it is possible that the hospital has been overpaid. This session will analyze some common situations and provide advice for developing factual and legal arguments that may eliminate the need to make a voluntary disclosure. It will also provide recommendations for how to handle situations that do require a refund. The session will include many examples, including a detailed discussion of a situation where the hospital fears that many " "short stays" " should have been treated as outpatient admissions.

You will learn the following:
  • How to recognize when the law requires a refund
  • Understand common mistakes made when making a voluntary disclosure
  • Learn the strategies for conducting internal investigations
  • Identify phrases that are helpful or harmful in letters to the government.

  • Meet Our Expert Speaker:

    David M. Glaser is a shareholder in Fredrikson & Byron's Health Law Group and helped establish its Health Care Fraud & Compliance Group. David assists clinics, hospitals, and other health care entities negotiate the maze of health care regulations, providing advice about risk management, reimbursement, and business planning issues. He has considerable experience in health care regulation and litigation, including compliance, criminal and civil fraud investigations, and reimbursement disputes. David's goal is to explain the government's enforcement position, and to analyze whether this position is supported by the law or represents government overreaching.
    Moderator: Nancy Collins, Publisher of The Journal of Medical Practice Management®