Emily J. Cook Emily J. Cook

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Emily J. Cook provides counsel to health care providers on complex regulatory and reimbursement matters. Her regulatory experience includes fee-for-service Medicare and Medicaid reimbursement, billing and coding, licensure, survey/certification and accreditation, and compliance with Medicare and state fraud and abuse requirements. She also has significant experience counseling health care providers and other stakeholder entities on issues related to 340B drug pricing program implementation, compliance and advocacy. Read Emily J. Cook's full bio.

New Guidance on Medicare Payment Rule Enforcement


By , , , and on Dec 5, 2019
Posted In Other Notable Enforcement Actions

A few days before Thanksgiving, the news media published an internal memo by the Office of General Counsel (OGC) at the US Department of Health and Human Services (Department) to officials at the Centers for Medicare and Medicaid Services (CMS). The memo expressed OGC’s views on the impact of the Supreme Court’s Azar v. Allina Health Services, et. al., No....

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Health Care Enforcement Quarterly Roundup | Q2 | July 2018


By , , , , , , , , , , , , and on Jul 18, 2018
Posted In Compliance Developments, Other Notable Enforcement Actions

How will key trends and developments in health care policy and enforcement impact future litigants? In the latest Health Care Enforcement Quarterly Roundup, we address this question in the context of: Continued interpretations of the landmark Escobar case The latest guidance from US Department of Justice (DOJ) leadership regarding enforcement priorities The uptick in state...

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New OIG Rules Change Patient Incentive Program Landscape: Where Are the Limits Now?


By , and on Apr 11, 2017
Posted In Anti-Kickback Statute / Stark Law

With health care becoming more consumer-driven, health care providers and health plans are wrestling with how to incentivize patients to participate in health promotion programs and treatment plans. As payments are increasingly being tied to quality outcomes, a provider’s ability to engage and improve patients’ access to care may both improve patient outcomes and increase...

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OIG Issues Report on Medicare’s ‘2-Midnight Hospital Rule’


By , and on Dec 30, 2016
Posted In Uncategorized

On December 19, 2016, the US Department of Health and Human Services Office of Inspector General (OIG) posted a report examining the Centers for Medicare & Medicaid Services’ (CMS’s) “2-Midnight Rule.” The OIG concluded that although the number of inpatient stays decreased and the number of outpatient stays increased under the 2-Midnight Rule, Medicare paid...

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