PRIMARYSETTLEMENT INCLUDES $, CORPORATE INTEGRITY AGREEMENT, MISDEMEANOR PLEA (OIG) NEW MODEL:DATA-DRIVEN REVIEW, RECOVERY OF IMPROPER PAYMENTS (RACs, Medicaid Integrity Contractors), FOCUS ON COMPLIANCE OUTLIERS IN PAYMENT AND QUALITY-ADMINISTRATIVE ACTION (CMS, state program integrity agencies);arbitrary and capricious CHANGING LANGUAGE IN MEDICARE AND MEDICAID PROGRAM CONTROLS • OLD LANGUAGE-”FRAUD AND ABUSE” • NEW LANGUAGE-”PROGRAM INTEGRITY, IMPROPER PAYMENTS” • “any payment that should not have been…
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