decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Voluntary Disclosure Program / Buyer Beware - Disclosing a Purchased Entity's Compliance Problems
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Article Overview
This article discusses a post-acquisition compliance problem in a healthcare setting and why voluntary disclosure to the OIG can matter when billing irregularities are discovered in a purchased entity. It is aimed at providers, compliance teams, and healthcare administrators evaluating risk after a transaction, and it covers broad enforcement considerations such as overpayment exposure, fraud-and-abuse concerns, successor liability, and the role of compliance remediation.
Why This Topic Matters
Healthcare acquisitions can surface hidden billing and documentation problems that may create significant regulatory and financial exposure. Understanding the general enforcement context helps organizations assess whether and how to respond when compliance issues are found after a purchase.
What You Will Learn
- How post-acquisition compliance issues can create regulatory risk
- Why voluntary disclosure may be considered after discovering billing problems
- How successor liability can influence enforcement considerations
- What broad factors may affect whether additional oversight is imposed
Who Should Read This
- Healthcare providers
- Compliance officers
- Revenue cycle staff
- Healthcare attorneys
- Practice managers
- Hospital administrators
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