Let’s face it—most healthcare organizations would rather do a group root canal than voluntarily tell the government they’ve made a mistake. The phrase “self-disclosure” doesn’t exactly scream “great career move,” and the idea of dialing up DOJ to say, “Hey,
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The Forgotten Innocent: When Health Care Providers Are Wrongly Accused of Faud!
Across the country, thousands of Medicare and Medicaid health care providers dedicate their lives to caring for vulnerable populations—seniors, people with disabilities, and low-income individuals who rely on government-sponsored health care to survive. Obviously I am not telling you novel…
Compliance. Because You Won’t Make It in Prison!
HHS Restructuring and Workforce Reduction: Key Changes and Uncertainties
By Miranda Franco, Senior Policy Advisor, Holland & Knight LLP On April 1, 2025, the U.S. Department of Health and Human Services (HHS) began implementing a significant reduction in force (RIF) following an announcement by HHS outlining a “dramatic…
Signed, Sealed, Exonerated: When a Law Firm Letterhead Sends the Auditors Packing
Most of my clients don’t call me because things are going well. No one rings up their health care audit lawyer just to say, “Hey, just wanted you to know I’m thriving!”
No, they call because they’ve received The Letter.…
Providers Under Siege: The Escalating Burden of Medicare Audits and the Threat of the False Claims Act

Healthcare providers have long navigated the complex world of Medicare audits, working diligently to meet billing standards, document patient care thoroughly, and respond to regulatory oversight. What once existed as a strictly administrative process is now evolving into something far…
April Fools’ Day and the Supreme Court: A 340B Comedy of Errors
Happy April Fools’ Day! In a move that shocked absolutely no one (except maybe a few overconfident pharmaceutical executives), the U.S. Supreme Court decided in December 2024 that it would not hear an appeal challenging an Arkansas law requiring drug…
Welcome to the Circus: The State of Healthcare in America
Ladies and gentlemen, step right up! You’ve heard of Cirque du Soleil, you’ve seen the greatest show on Earth, but nothing—absolutely nothing—compares to the high-flying, death-defying, logic-defying spectacle that is the American healthcare system. And in this act, our fearless…
Trump’s Deregulations…But Not in Health Care Fraud Detection!
As we don our green attire and raise a glass to St. Patrick’s Day, it’s worth pondering what luck—or lack thereof—a second Trump administration might bring for healthcare providers. While some may hope for the four-leaf clover of regulatory relief,…
Challenging CMS’ Recoupment Before Full Adjudication: A Constitutional Perspective
The Centers for Medicare and Medicaid Services (CMS) has the authority to recoup alleged overpayments from healthcare providers before the full adjudication of an appeal. While this practice is legally sanctioned under federal regulations, it raises significant constitutional concerns, particularly…