Dennis Sapien Pangandian
speaker
184 appearances
1 recordings
1 series
first heard Jul 2026
last heard 31 Jul
Dennis Sapien Pangandian’s voice in public audio — every appearance, attributed to the second.
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recordings per month · last 12 monthsRecordings per month over the last 12 months — 1 in all, peaking in Jul 2026 with 1.
Appearances
And those are very similar to the same actors.
If you're a
ever familiar with OIGCMP authorities generally, it's pretty much the same type.
Factors that OIG considers, the nature and duration of the conduct, the level of intent, the harm it caused, whether it was a pattern or a practice or just a single instance.
To the extent of, you know, during the investigation, whether or not a target or a defendant was cooperative or taking any remedial measures.
So that's generally what OIG considers when applying CMPs across the board.
And that's not going to be any different here.
Yeah.
Yeah, for health lawyers that are in the lingo, right, I think the best way to think about this is it's most analogous to the anti-kickback statute more so than to Stark Law.
It's not a strict liability issue.
And this is also where the type of act that you are determines the level of intent that's required by the government.
to prove.
So if you're a health IT developer, if you're an HIN, if you're an HIE, the practice that you're allegedly engaging in, if that actor knows or should know that
their practice interferes with the access, exchange, or use of EHI, then that's a violation, right?
But for healthcare providers, there's a higher level of knowledge and there's a higher standard of knowledge that needs to be applied.
They have to actually know that this practice interferes with the exchange of EHI.
And I think that was meant to capture the fact that healthcare providers, their primary concern is to be a healthcare provider.
They're taking care of patients.
They're not health IT developers.
And again, this goes back to the thing.
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