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

But those five laws are the False Claims Act, the

Physician self-referral law, also known as the Stark Law, the federal anti-kickback statute, we have civil monetary penalties, and then we have the exclusion authorities.

Those are all great points to start.

Now, if we're thinking about the False Claims Act, what are we looking for?

A false or fraudulent claim that is being submitted, either for services that were never provided or for services that have requirements, but not all of the requirements have been met.

Or lastly, implied certification, which was the Escobar case, which, Pam, to your point, we could completely see.

If a medical assistant is billing for an MP, then that's what was at issue in the Escobar case.

You had non-qualified providers, meaning that they were acting outside of the scope of their license, utilizing someone else's.

number in order for that claim to be submitted.

And that's where the implied came in because you shouldn't have to say you need to be qualified in this area of medicine in order to submit the claim, right?

But

That's what happens.

Yeah, one thing before I delve into the family clinic of Albany versus the

Charts ban medical technologies case is

Having read a variety of these contracts, so from the legal side, another area that I would caution any provider and or lawyer who's reviewing those contracts is

Is there a

fee sharing which isn't

completely impermissible if you construct it within Stark and AKS that may be permissible.

But when I see a shift in fees

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