Rachel V. Rose

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233 appearances 1 recordings 1 series first heard Jul 2026 last heard 24 Jul

Rachel V. Rose’s voice in public audio — every appearance, attributed to the second.

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Recordings per month over the last 12 months — 1 in all, peaking in Jul 2026 with 1.

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AHLA's Speaking of Health Law · Navigating the CCM and RPM Landscape · 24 Jul 2026 podcast

Having said that, there are really three things that stood out to me about the judge's opinion in the motion to dismiss.

First, he did allow for the individual owner of the chart span company to be removed as a defendant.

He left intact the liability with the LLC chart span itself.

Secondly, there was the allegation of unclean claims to

CMS for reimbursement, meaning as you led with Pam, they weren't meeting those core three criteria.

And then lastly, they they offered direct or indirect remuneration in violation of the federal anti-kickback statute.

So the AKS

Remuneration can be direct or indirect in cash or in kind and influences either the utilization of a service or a product or

or the referrals of a service of a product for any government program with the exception of the in federal employee health benefits program.

So what

The judge said was that relators you can proceed.

on the claim that charts chart span personnel, and this goes to your last point, did not meet the Medicare standard for CCM services to patients by routinely failing to make any actual communication.

And it's important to note communication again can be

via text message, it can be through your EMR, it can be via phone or audio visual, but there has to be some form as well as routinely failing

to provide management of patients' chronic conditions, having little to no health information to actually manage, and also

The

numeric portion like you were saying, how did these people get to twenty minutes a month?

So with that, and since we're near the end of our time pam, I will just wrap up with our core takeaways.

First and foremost, when creating a compliance program.

I know your go to, my go to is forty two CFR four eighty three point eight five, and that provides seven.

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