Fraud and abuse compliance programs: their time has come

Abstract

Two recent developments in Federal law enforcement should prompt healthcare providers to establish or augment programs to detect and prevent Medicare and Medicaid fraud and abuse. New and controversial Federal sentencing guidelines require judges to impose multi-million dollar fines on companies convicted of certain Federal crimes, and substantial civil monetary penalties may be imposed for violation of the Medicare and Medicaid fraud and abuse laws. One of the ways to avoid these penalties is to establish an effective compliance program designed to prevent criminal conduct before it happens.