Erica L. Gnilka
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Erica L. Gnilka provides counsel to health systems, physician groups and other health care providers on complex regulatory issues. Erica’s practice includes advising clients on issues related to federal and state health care program enrollment and reimbursement, as well as fraud and abuse issues arising under the Stark Law, the Anti-Kickback Statute and accompanying state statutes. Read Erika L. Gnilka's full bio.
By Erica L. Gnilka on Jun 13, 2018
Posted In Medical Necessity, Sampling/Extrapolation
On April 2, 2018, the magistrate judge for the US District Court for the Southern District of Indiana issued an order refusing qui tam relators’ request to conduct discovery related to claims submitted to Medicare on a nationwide basis in an ongoing False Claims Act (FCA) case. Importantly, the judge considered whether statistical sampling could...
‘Tis the Season for Giving: OIG Updates Policy on Gifts of Nominal Value to Medicare and Medicaid Beneficiaries
By Erica L. Gnilka, Joan Polacheck, Kelsey Leingang and Monica Wallace on Dec 12, 2016
Posted In Anti-Kickback Statute / Stark Law
On December 7, 2016, the Office of the Inspector General (OIG) of the US Department of Health and Human Services (HHS) issued a policy statement increasing its thresholds for gifts that are considered “nominal” for purposes of the patient inducement provisions of the civil monetary penalties law (section 1128A(a)(5) of the Social Security Act) (CMP...