First Healthcare Compliance CONNECT April 2023

CONNECT 

April 2023 

 

A Quarterly Publication for the Healthcare Compliance Community 

Infographic: 

Healthcare Compliance: 

Costs vs Benefits 

Healthcare Compliance 

Policies: Best Practices for 

Management and Distribution 

Legal Risks With Health 

Data Sharing: Q&A 

Transcatheter Valvular 

Procedure Code Set 

Updates 

How to Protect Your 

Healthcare Assets: Q&A 

1st Talk Compliance: 

DMEPOS – 

In Compliance with CMS

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In This Issue: 

Infographic: Healthcare Compliance: Costs vs 

Benefits 

Healthcare Compliance Policies: Best Practices 

for Management and Distribution 

Legal Risks With Health Data Sharing: Q&A 

Transcatheter Valvular Procedure Code Set 

Updates 

2 

Panacea Healthcare Solutions LLC © 2023

Compliance Super Ninja 

Mia Higgins 

Director, Client Services, McEwen and Associates 

How would you describe your experience with First Healthcare 

Compliance? 

Terrific! It has made my work life so much easier. First Healthcare Compliance has 

everything you need in one space. It would take me hours at times to search for answers but with their free 

resources you find everything you need with ease! 

What do you enjoy most about working with McEwen and Associates? 

The people. My team is so important to me, we are a family. I enjoy watching my team grow and building longlasting 

relationships with our clients. 

Would you rather be completely invisible for one day or be able to fly for one day? 

Why? 

I’d rather be completely invisible for one day. I love Halloween and being invisible would allow me to scare my 

family and pull a few pranks on them. I get motion sickness so flying would be out of the question! 

How to Protect Your Healthcare Assets: Q&A 

1st Talk Compliance: DMEPOS – In Compliance 

with CMS 

Contact Toll Free: 888-54-FIRST 3

FAQ Corner 

How should we handle employees who won’t complete training as assigned? 

Compliance should be a condition of employment. And as part of the Code of Conduct sample we provide, 

employees are required to complete compliance training. Employers may wish to enforce their training 

requirements through discipline. Discipline may include a verbal warning, written warning, suspension, up to and 

including termination. Of course, if your organization has a progressive discipline policy, it must be followed when 

disciplining employees (we provide a sample compliance program disciplinary action policy within the Compliance 

Policies and Procedures Sample). It is also important to be consistent in meting out discipline so as not to run 

afoul of discrimination laws. 

Explore the FAQs tab in your compliance solution 

to find answers to your compliance questions! 

CLIENT 

ALERT 

Navigating Workplace Violence 

Prevention Under OSHA 

Workplace violence is a serious issue, especially 

in healthcare facilities. The OSHA workplace 

violence prevention guidelines help employees and 

employers alike by providing the necessary steps 

to maintain a safe work environment. 

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4 


Healthcare Compliance: 

Costs vs Benefits 

Within the healthcare industry, the focus has increasingly turned toward compliance, and 

there are multiple regulations that prompt the need for implementation of an effective program. 

COSTS of Being Reactive 

BENEFITS of Being Proactive 

It's the law, so criminal 

charges come into play. 

Enforcement has been 

increased over the last 

several years. 

Reputation matters more 

than ever. News travels fast 

and a physician's reputation 

has a direct impact on the 

success of the practice. 

Patient outcomes 

may be affected by 

lack of safety. 

Staff confidence and 

morale will benefit from 

extra training and knowledge. 

"Knowledge is power" is 

especially applicable in 

any medical setting. 

Showing that you've 

commited time and 

resources to compliance 

shows the community and 

your staff that you believe 

in doing things the right way. 

The impact may be 

monetary via fines 

and penalties. 

Having a full compliance 

program in place leads 

to better communication 

and uncovering potential 

problems. 

Comprehensive Healthcare 

Compliance Management Solutions 

CONFIDENCE INCLUDED 

Creating confidence among 

compliance professionals through 

education, resources, and support 


Healthcare Compliance 

Policies: Best Practices for 

Management and Distribution 

First Healthcare Compliance Staff 

Purposes of Policies in Healthcare Organizations 

Many healthcare organizations operate under a comprehensive set of policies and procedures that address 

a wide range of compliance-related issues, including physician relationships, conflicts of interest, OSHA and 

HIPAA Privacy and Security. These policies and procedures should be available to every employee and provider. 

Specific standards set by an entity as well as the elements of an effective compliance program provided by OIG/ 

HHS offer frameworks for roles and committees to ensure consistency and integration of compliance activities 

and the effectiveness of the overall compliance program. 

A well-managed set of policies is critical to the well-being of any healthcare institution. Proper policies support 

activities by communicating expectations, establishing a culture of compliance, protecting in litigation matters, 

and ensuring the welfare of patients and staff. 

Important purposes of policies in the healthcare setting include: 

1. Provide the framework for the key elements of the compliance program 

2. Promote and support ethical behavior among staff 

3. Exhibit commitment to compliance and all regulations governing the organization 

Management and Distribution of Healthcare Compliance Policies 

In addition to creating, communicating, and maintaining policies within a healthcare organization, it is imperative 

to take steps to manage and distribute the policies effectively. 

Assign Responsibility 

An individual should be responsible for managing policies within the healthcare organization. Depending on 

6 


the size of the entity, it may be either a full or part time position. 

Control Access 

For the purposes of efficiency and privacy and security, the administrator should have full control when it 

comes to providing access for reading and editing policies. 

Track Policy Updates 

Tracking policy changes becomes a necessity to provide accurate information to compliance questions or 

auditors. 

First Healthcare Compliance offers several solutions that provide customizable sample Policies and Procedures. 

In addition, our Document Storage zone allows compliance personnel to upload, organize and distribute 

documents via the Training Zone for employee attestation. To learn more contact us today! 

The Most Comprehensive 

Healthcare Compliance Course 

The Fundamentals is a 

user-friendly, four-module 

online course designed to 

help healthcare professionals 

understand the essential 

principles and practices of 

compliance. 

BUY COURSE NOW 


Legal Risks 

With Health 

Data Sharing: 

Q&A 

Catherine Short 

Iliana L. Peters, Shareholder at Polsinelli PC, believes 

good data privacy and security is fundamental to 

ensuring patients’ trust in the health care system, and to 

helping health care clients succeed in an ever-changing 

landscape of threats to data security. She is recognized 

by the health care industry as a preeminent thinker and 

speaker on data privacy and security, particularly with 

regard to HIPAA, the HITECH Act, the 21st Century Cures 

Act, the Genetic Information Nondiscrimination Act (GINA), 

the Privacy Act, and emerging cyber threats to health data. 

For many years, Iliana both developed health information 

privacy and security policy, including on emerging 

technologies and cyber threats, for the Department 

of Health and Human Services, and enforced HIPAA 

regulations through spearheading multi-million dollar 

settlement agreements and civil money penalties pursuant 

to HIPAA. Iliana also focused on training individuals in 

both the private and public sector, including compliance 

investigators, auditors, and State Attorneys General, on 

HIPAA regulations and policy, and on good data privacy 

and security practices. 

As a member of the First Healthcare Compliance Editorial 

Council, Iliana is a frequent presenter at educational 

events. For more information regarding this topic please 

view the related webinar for further discussion and 

learning. 

Below, Iliana answers some common questions 

and provides explanations related to the education 

surrounding Health Data, A Value Proposition: Legal Risks 

with Innovative Data Sharing Projects. 

Can you give us an overview of the health data value 

proposition, what some of the legal risks are with 

data sharing projects? 

This is a new and evolving area of practice, particularly 

because we have many different entities that are very 

interested in engaging in innovative data sharing projects 

that result from the need to do research of all different 

types. This includes research with a small “r,” in terms 

of research and development within entities, and the of 

development of new products and services. And this also 

includes Research with a big “R,” that is human subjects 

research, as defined under the law, that may be used to 

determine new therapies, new drugs, new devices for 

patients, as well. There are all kinds of research projects 

going on related to the use of data, and for many different 

important reasons. And as a result, we’re seeing a lot 

of questions about the legal requirements and risks 

associated with those types of projects, and particularly 

the agreements that are necessary and being put in place 

between business partners related to those projects. 

Can you give us a summary of the legal issues 

involved in data sharing projects and do you think 

there are serious legal risks associated with some of 

these issues and projects? 

8 


The short answer is, yes, there is serious legal risk. There 

are state, federal or international legal requirements 

related to how we can use and disclose data. That 

includes a general prohibition on the sale of data. Many 

of these innovative projects include some kind of benefit 

to the entity originating the data, because the entity is, in 

fact, contributing data to an important project that’s going 

to arguably result in a new service or a new application. 

As a result, these agreements contemplate direct or 

indirect remuneration, that is, some kind of benefit to 

the entity that’s originating the data. This is considered 

a sale of data. That would necessitate consent from the 

individuals whose data is being using for these projects. 

It is important that entities understand what this looks 

like, from a legal perspective, because of those risks. As 

a result, a lot of entities are anonymizing data so that we 

can use data for projects involving remuneration without 

implications for patient privacy, because the patients are 

arguably not identifiable, or we don’t know who those 

patients are as part of those projects, because we’ve 

anonymized the data. 

Obviously, if we’re going to do that, we have to make sure 

that we do that properly, in a way that doesn’t allow for 

those individuals to be identified, doesn’t allow business 

partners or downstream users of that data, to re-identify 

or recombine data with other data sets to figure out who 

those people are. This is not easy; it’s a difficult issue. 

Additionally, we have contractual requirements with our 

own clients and business partners that may significantly 

restrict how we can use data, how we can put data 

together and datasets, and how we can anonymize the 

data. For example, Centers for Medicare and Medicaid 

Services have significant prohibitions in agreements 

related to Medicare and Medicaid beneficiary data that we 

have to be aware of when we’re aggregating data or deidentifying 

it. We generally can’t use CMS data in that way. 

That’s just one example from a contractual perspective. 

And then, of course, we have data breach issues. Anytime 

we’re putting together lots of data into a big data set, that 

becomes a target for a cyber-criminal or threat actor. We 

have to be very cognizant of the risks there, particularly 

if we’re providing that data outside our entity, to another 

Risk Management Considerations for the 

Healthcare Compliance Officer: 

Training, Incident Management, 

Governing Boards, and Measures Unique 

to COVID-19 

It’s no secret that healthcare is one of America’s 

most heavily regulated industries with substantial 

fines and penalties for non-compliance. Complex 

regulations and mandates make compliance 

management a necessity. 

DOWNLOAD NOW 


usiness partner, who’s then going to have our data and 

be subject to those risks. 

Finally, there’s always a reputational issue, even if we do 

everything in a legal way. Even if we protect the data from 

a data security perspective, individuals could still find out 

about how we’re using their data, because maybe it’s not 

identifiable, maybe it’s anonymized data, but it still came 

from them originally. And they can feel very strongly about 

how we’re proposing to use data for a particular project. 

Maybe they don’t agree with a particular project, for 

whatever reason. That could also create reputational risks 

for us. 

These are all these risks that we have to consider, from 

an underlying legal perspective, a contractual perspective, 

about data ownership, and about data licensure; all of 

those important controls that we put in place for data 

security purposes. Then just considering what the 

consumer would feel about a particular data project to 

make sure that we consider their viewpoints on these 

projects as well. 

What are the most important risks to consider in 

innovative data sharing projects? 

I think the most important risks are the risks associated 

with how the business partners that you’re working 

with are going to use your data. At the end of the day, 

making sure that we understand the data ownership and 

licensure issues, particularly with regard to the type of 

data that we’re using for any particular project is critical, 

so that we can ensure the right controls for that data. We 

want to make sure that we appropriately take care of that 

data. Arguably, we can control how we use our own data. 

It’s really about when we share that data with business 

partners, how we do our best to make clear to those 

business partners how we expect them to use and share 

our data and how we expect them to protect it. It’s about 

making sure they understand our ownership of the data, 

what the license to the data looks like, for purposes of a 

particular project, and how they’re going to protect the 

data, as they hold it. I would say that’s the largest risk, 

when we share that data outside of our own institutions. 

COVID-19 Healthcare 

Compliance Updates 

In response to the global outbreak of the novel 

coronavirus disease (COVID-19), the Secretary 

of Health and Human Services declared a public 

health emergency on January 31, 2020. Federal 

agencies have taken action by issuing updates and 

guidance to navigate the crisis. This ebook provides 

healthcare providers with important developments 

and resources that impact federal healthcare laws. 

DOWNLOAD NOW 

10 


Have you heard 

our big news? 

First Healthcare Compliance is now part of 

the Panacea Healthcare Solutions family! 

At First Healthcare Compliance, our 

mission has always been to provide 

healthcare entities with the tools and 

resources they need to ensure compliance 

with regulations and industry standards. 

Now, as part of the Panacea Healthcare 

Solutions family, we're taking this mission 

to the next level. 

Panacea's state-of-the-art strategic pricing 

and auditing solutions are now combined 

with First Healthcare Compliance to offer 

the best-in-class solutions. This 

collaboration brings together the expertise 

of two leading companies to deliver 

unparalleled solutions that meet the 

unique needs of healthcare organizations 

nationwide. 

With Panacea's cutting-edge mid-revenue 

cycle software and technology-enabled 

solutions, we offer a comprehensive suite of 

compliance services that streamline your 

workflows and enhance your bottom line. 

Our team of experts is committed to 

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landscape of healthcare compliance. 

Join the many healthcare organizations 

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Contact us today to learn more about how 

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panaceainc.com | (866) 926-5933 | contact@panaceainc.com 

Software. Consulting. Education. Results. 


Transcatheter 

Valvular Procedure 

Code Set Updates 

New Technologies and the 

Codes You Should Capture 


Over the last decade, one of the most exciting areas 

of development in healthcare has been the growth 

of structural heart and interventional cardiology 

programs—specifically, the advancement of 

transcatheter valvular procedure techniques. 

There has been significant scientific advancement 

in these techniques since the transcatheter valvular 

procedure code set was initially developed, including 

the establishment of clinical trials testing new 

treatment methods and devices. The complex 

nature of these treatment programs and the rapid 

advancements in treatments and technology have led 

to the development of some very complicated coding 

rules and coverage requirements from CMS and other 

payers. 

As the ability to treat a larger population using 

these novel techniques expands, so must 

our understanding of the nuances involved in 

navigating the current rules and regulations from 

both the clinical and revenue cycle perspectives. 

In case you missed our webinar on the subject, you 

can review the material covered during the live session 

by referencing an eBook of the presentation content. 

Read through for an overview of the following topics: 

• How transcatheter techniques are reshaping 

treatment options 

• Cardiac anatomy 

• Transcatheter valve procedures and clinical trials/ 

data registry requirements 

• Successful clinical trial information capture 

• Sample claims 

• CPT code set 

• Key resources 

READ MORE 

12 


Referral Appreciation Program 

Receive a $50 gift card* when you refer a client! 

First Healthcare Compliance is delighted to offer a 

Referral Appreciation Program to say thank you for 

helping us to continue to grow. For each new 1st 

Professional or 1st Premium client originating from a 

referral, First Healthcare Compliance will provide a 

$50 gift card as a token of appreciation. 

LEARN MORE 


How to Protect 

Your Healthcare 

Assets: Q&A 


Highly-regarded attorneys Sean McKenna, Lauren 

Nelson, and Vincent Aiello of Spencer Fane LLP 

recently held the comprehensive webinar Preserving 

and Protecting Assets in Healthcare joined by Catherine 

Short and First Healthcare Compliance. Please see their 

bios at the end of this page. 

Continue reading for Sean, Lauren, and Vince’s lively 

question and answer session related to enforcement 

and liability proceedings with asset protection, and 

explore government and private litigation matters. 

What do you need to do in order to protect 

yourself from government investigations? 

Lauren: 

The government has really ramped up their civil and 

criminal investigations over the last year or two. And 

they have new initiatives that are really focused on 

recovering money spent on these alleged fraudulent 

claims. In the last year, they’ve really been focusing 

on telehealth claims submitted by labs, as well as 

pharmacies. And they’ve started the investigations into 

COVID funding and billing, as well as your PBMs. We 

expect the government will continue to ramp up the 

investigations in these areas as well as other potential 

areas. In addition, the different licensing boards 

have also resumed their unannounced surveys and 

inspections of provider sites. 

To help protect yourself from investigations, the first 

thing is to have a full understanding of what these 

different potential risks are. To do this, you need to do 

a comprehensive and very strategic assessment of all 

potential risks throughout your organization. Frequently 

people talk about enterprise risk management. It really 

is a great approach because it looks at every different 

department of a health care system. And it’s important 

that not only do you do these risk assessments in 

each department, but you need to have the different 

groups communicate and work together. So, there’s 

coordination and a real appreciation for what those 

risks are. 

Lauren, can you speak to the risk factors 

or components of a smaller organization 

versus those of a large institution or national 

company? 

Lauren: 

Yes, absolutely. It’s really about understanding what 

those potential risks are. If you can coordinate the 

efforts of these assessments, with the different 

departments you’re in, you will end up putting less 

strain and demand on the individual departments. And 

that results in a better understanding of the potential 

risks. It also gives you the capability of improving 

those potential problems that you can identify. One 

14 


ig area, as a defense attorney, I frequently deal with 

are patient medical records, and I always deal with 

risk management. What can be a little problematic 

is when there’s a lack of coordination between the 

IT department or the records department, and risk 

management. So, it’s important that everyone’s on the 

same page, and has a good understanding of what 

information is available. 

What are common compliance issues you see 

in your practice, Lauren? 

Lauren: 

So, common compliance issues that we see… and 

I’m not going to list out every single one of these, but, 

common problems are issues with inappropriately 

providing copay assistance, not adhering to a contract, 

having a commercially unreasonable arrangement, 

retroactive payments or adjustments and things like 

that. 

Sean, I’m sure you see a lot of this in your 

practice, right? 

Sean: 

Yes, absolutely. One of the biggest concerns from a 

compliance perspective that translates into potential 

monetary damages are these per click percentagebased 

arrangements. Those have been frowned on, 

they’ve been deemed non-compliant by Department of 

Justice and OIG in various states. We’re seeing a lot of 

those cases. Also, joint ventures. Those will continue 

to be at risk, the OIG has said. For decades, these 

are all Hot Topic issues along with those sectors that 

are being scrutinized that could result in some sort of 

monetary penalty or financial hit, not just monetary, 

but could be institutional, goodwill, morale, etc., all 

could have an impact on providers’ bottom line and 

could result in some sort of default, or some sort of 

other potentially private liability on the quality side. 

Vince, can you discuss enforcement and 

potential liability, especially during the 

pandemic and onwards? What can you talk 

to us about kind of what individuals and 

executives and company’s clinicians can do to 

protect and preserve their assets? 

Absolutely. Before we get going into asset protection 

trusts, and some asset protection strategies, there’s 

a few caveats: one, asset protection, asset protection 

strategies work best when planning ahead. If you’re 

thinking that you’re going to set up an asset protection 

trust, at the last minute, after a claim has been filed, 

after an investigation has started, that’s generally a 

huge red flag. 

If you’re not setting these trusts up at least a minimum 

of two years before any potential claim, then there’s a 

risk that they may not work. Also, these types of trusts 

aren’t a panacea to simply skirt liability and somehow 

say that you can engage in nefarious conduct or things 

that are criminal in nature. They don’t function in that 

capacity. With those sort of basic caveats in mind, I 

can kind of walk through the process of setting up 

an asset protection trust and what it is and what’s 

involved with that. Asset protection trusts have been 

around for quite some time, in their simplest way to 

think about them, they are a contract, there is a trust 

agreement, and they are a creature of statute, they are 

almost always an irrevocable trust. They are set up 

under the laws of particular states. Legislatures have 

expanded the scope of protections in various states 

and offer various degrees of creditor protection for the 

individuals that are setting up an asset protection trust. 

An asset protection trust, essentially is a contract 

document. It allows you to preserve your assets, retain 

beneficial interests of those assets, and protect the 

assets from creditors. It’s highly effective if they’re 

set up ahead of time for entrepreneurs setting up all 

sorts of businesses, medical practices, medical service 

organizations, for business owners, for the individual 

employees that are functioning as directors or officers, 

CEOs, for doctors, and generally used for individuals 

with higher net worth. You’re not going to see an asset 

protection trust set up in a scenario where you are 

trying to preserve a few $100,000 in assets. Usually, 

these are going to be folks who have a few million 

dollars at risk and you’re setting it up to mitigate any 

potential risk of liability seizure and forfeiture that 

may come from all the things that Lauren and Sean 

discussed. 


You mentioned potential red flags. What are 

the consequences when you see all these red 

flags? What can happen? 

Vince: 

Oftentimes, folks will come to me and they’ll say I 

want to set up an asset protection trust and I want to 

control everything. That’s a huge red flag. You’re going 

to have to be comfortable with moving your assets into 

an irrevocable asset protection trust, to preserve those 

assets for your benefit, but you can’t retain too much 

control over those assets. And this is sort of where 

Catherine nuances Short of state law and trust drafting come into 

play. And really, it goes to how these documents aren’t 

formulaic. They need to be set up for the individual 

business owner, the professional doctor or person that 

is potentially subject to the to the liability of running a 

medical organization, doctor’s office and whatnot. 

So, there are lookback periods, and the red flag that 

happens is that the doctor or business owner comes 

in and they say, “I think I’m under investigation, but 

I’m not sure.” And then, all of a sudden, they’ll say, 

“We need to take certain steps to protect my assets. 

I’ve never done that before, I have an LLC, but I’m 

concerned, I may have some liability.” If you race to set 

up an asset protection trust after the fact, both a civil 

attorney and a criminal prosecutor can file motions to 

have the judge look at the transfers into those trusts 

and set those transfers aside, essentially unwinding 

the value in the benefit the trust offers. 

So, for example, in Nevada, and several other states, 

the look back period is two years. If a client comes 

to me today, and they want to start a new medical 

practice group, and they’re concerned about potential 

liability, perhaps they’ve invested a million dollars into 

the business, and they don’t want to lose the balance 

of their investments and holdings, they will want to set 

up this trust. As long as they’re doing that two years 

before they incur any potential liability, then they’re fine. 

Sean, could you discuss on civil forfeiture 

because of your background and what you 

focus on in your practice? 

Sean: 

Civil forfeiture essentially means that we think there 

may be some sort of illegal, ill-gotten gains, and 

we’re going to take it until you claim it, and then have 

to justify how it’s not. And so now the burden shifts 

entirely on the individual whose funds have been 

seized. And this is a favorite of local law enforcement, 

as well as the feds, they can go in, along with a search 

warrant, or just on their own and seize a bank account, 

for instance. And then you must administratively make 

a claim and then litigate it as a mini trial and basically 

justify your existence. So, it’s extremely burdensome 

for an individual or business to try and justify and 

explain. It’s an exorbitant amount of time and effort 

to try and do a tracing or not tracing. Sometimes you 

can negotiate it and sometimes you can’t. But civil 

forfeiture is a very powerful tool for the Department 

of Justice (DOJ) and its agencies. You know, DEA, FBI, 

IRS, are the ones that typically use is the most. 

What’s ahead, Lauren, any predictions for the 

year? 

Lauren: 

Sure. So, there are predictions that due to patients 

delaying receiving care, over the last couple of years, 

because of the pandemic, health care providers are 

anticipating an increased need for care, especially in 

the long-term care sector as well as care for chronic 

diseases, as well as behavioral health. And one thing 

that will be interesting to watch over the rest of the 

year, is the further integration and diversification of 

how that care is being provided. So, through telehealth, 

the integration from wearable devices and things like 

that, which, those issues, raise cybersecurity questions. 

There’s also a thought that there will be a greater level 

of investigation by the government and there’ll be 

greater scrutiny for FCA and AKS. 

16 


Vince, do you have further thoughts on our 

topic? 

Vince: 

I think my final thought is to plan for the future. In my 

practice, that’s key. If you’re in business now, and you 

haven’t planned, and you’ve got a concern, if you think 

you’ve got exposure, still plan now. It’s not too late. 

Whatever the big scary liability is that that is out there, 

there are ways to deal with that. It’s very unfortunate 

when folks come to my office too late. There’s very 

little we can do after the fact. So, that that’s my 

suggestion. 

Sean McKenna, Lauren Nelson, and Vincent 

Aiello of Spencer Fane LLP 

With 24 years of experience, 

Sean McKenna is a nationallyrecognized 

defense attorney 

who focuses his practice 

on defending executives 

and providers in healthcare 

enforcement, litigation, and 

regulatory issues, under civil or administrative 

investigation by the U.S. DOJ, OIG, and Attorneys’ 

General Medicaid Fraud Control Units, as well as in 

criminal investigations and matters involving federal 

and state governments. As a former ten-year Assistant 

United States Attorney, Associate Counsel to the 

Inspector General, and General Counsel for the U.S. 

Department of HHS, Sean also assists clients with 

internal investigations, compliance reviews, as well 

as advising on their compliance with state and federal 

fraud and abuse rules. 

Lauren M. Nelson has 16-years 

of experience litigating 

across the country on behalf 

of healthcare providers 

and executives, including 

hospital systems, physicians, 

rehabilitation centers and other 

providers in complex medical malpractice actions, 

licensing matters, and other business disputes. She 

specializes in a variety of cases, from catastrophic 

birth and spinal cord injuries to misdiagnoses and 

failures to treat. Lauren also counsels and represents 

physicians and nurses before State and federal 

regulators and licensing boards in all manner of 

investigations, reviews, and inquiries. 

Vincent Aiello helps business 

owners solve legal problems 

to secure revenue flow and 

reduce business risks. As a 

lawyer and business owner 

he has firsthand experience 

handling complex commercial 

litigation and transactional matters for his clients. His 

client base spans a broad spectrum of businesses 

including household-name consumer brands, banks, 

construction companies and family ventures. As legal 

counsel, he advises personal family foundations on 

managing and protecting their wealth. While each of 

his clients may take on a unique shape or size, they all 

face complex legal and business challenges, which is 

precisely where Vincent has focused his commercial 

legal practice. 


hosted by Catherine Short 

1st Talk Compliance features guest Rachel V. Rose, JD, MBA, principal with Rachel V. Rose – Attorney at 

Law, P.L.L.C., on the topic of DMEPOS – In Compliance with CMS. Rachel joins our host Catherine Short 

to discuss special payment rules associated with durable medical equipment, prosthetics, orthotics and 

supplies. DMEPOS products must meet quality standards, suppliers need to be accepted by Medicare to 

participate, similar to providers, and are subject to fraud, waste, and abuse laws. This episode will provide 

an overview of participation and quality requirements, relay the latest compliance and requirements updates, 

and discuss the consequences of non-compliance, as well as submitting false and fraudulent claims. 

Listen weekdays at 

7:30am, 3:30pm, 11:30pm ET 

Check out our Show Page! 

Looking for the latest compliance insights? 

Subscribe to our feed and don’t miss a thing! 

18 


WORD SEARCH 

K H M P C F R L M M H E C F C H Q A R V 

G X P T V B I U V L D W Q J Q L S P S K 

Y T T R S W A S T E O K S Z W B A T N H 

F N U A T I D B S V J S G O S R E G O Q 

C E W N W K O O S E Y L F S E D R V I X 

E M G S O E E Q B O R N K S I B W Z T Y 

Z E J C S N Z F L N L U O X G M X Y A T 

Y G P A M I D L R M V U D D M K H C Z M 

H A D T D L Z E Y V R W T E Q L Y O I J 

B N S H U P M F C C C G N E C G J X N K 

Z A N E N I E W E R P W P K L O D M A Z 

A M O T E C I S D T I O T A C Y R Q G H 

L I I E S S F E H K L Q Q P S V V P R G 

B U T R U I W M I I Z U J Z L I O H O W 

L A C C B D W E C N A I L P M O C L H L 

L D I J A I D I Q L B R W Y S R G J F X 

R M D D I I E R I R O X L T L W X J T H 

M L E I N S D T E R A C H T L A E H E X 

P T R Z H X Y Q E C X Z S B F R A U D J 

X I P M X Z L X R O L C L D T K X W X U 

MANAGEMENT ORGANIZATIONS PROCEDURES 

COMPLIANCE QUALITY FRAUD 

WASTE ABUSE PREDICTIONS 

HEALTHCARE ABSOLUTELY TRANSCATHETER 

DISCIPLINE POLICIES RESOURCES 


Upcoming and On-Demand Webinars 

Training 

MAY 16, 2023 

ON DEMAND 

ON DEMAND 

ON DEMAND 

ON DEMAND 

ON DEMAND 

The Increasing Role of the Federal Trade Commission in 

the Poaching of PHI - A Discussion of Better Help, 

GoodRx & Flo 

False Claims Act “Hot Areas” – What You Need to Know 

Transcatheter Valvular Procedure Code Set Updates: New 

Technologies and the Codes You Should Capture 

The Safe Harbor Law: A Practical Approach 

The Criminal Side of Cybersecurity and HIPAA 

Evaluation and Management Updates 2023: Training and 

Q&A 

Register 

All Upcoming Webinars 

All On Demand Webinars 

IMPORTANT 

In the interest of your security, login credentials 

are for individual use only and not to be shared. 

Please contact Client Services if you require 

additional manager level users and/or if there has 

been a change in contact information. 

NEW FEATURES! 

Training Zone- Automated Training Zone Reminder 

emails are now being sent at the halfway point and 

the day before expiration. Please contact Client 

Services if you would like to inactivate this feature. 

Training Zone - Employee Activated Status 

has been added to the Training Zone 

landing page view. 

CLIENT 

ALERT 

Employee Incident Reporting - This new feature will 

provide the option for Employees to open/create an Incident 

Report. When employee incident reports are created you can 

review, update, track and manage them within the Incident 

Reporting Zone. Contact Client Services if you are interested 

in adding this additional feature to your Incident Reporting 

Zone. 

Join us on Social Media! 

Contact our Client Services Team with your questions! 

888.54.FIRST or clientservices@1sthcc.com 

20

First Healthcare Compliance CONNECT April 2023

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