Jason B. Caron
Subscribe to Jason B. Caron's PostsJason B. Caron provides strategic advice to health care and life sciences organizations, primarily focusing on regulatory, reimbursement and policy matters. He has extensive experience navigating coding, coverage, payment, medical necessity, clinical documentation, comparative research, certification, enrollment, and other payer participation and reimbursement issues, particularly in light of ongoing health reforms. Read Jason B. Caron's full bio.
OIG Seeks Comments on Anti-Kickback Statute and Beneficiary Inducements as Part of its Regulatory Sprint to Coordinated Care
By Amy H. Kearbey, Daniel H. Melvin, Eric B. Gordon, MD, Jason B. Caron, Joan Polacheck, Monica Wallace and Tony Maida on Aug 27, 2018
Posted In Anti-Kickback Statute / Stark Law, Compliance Developments
On August 24, 2018, the Office of Inspector General (OIG), Department of Health and Human Services (HHS) published a request for information, seeking input from the public on potential new safe harbors to the Anti-Kickback Statute and exceptions to the beneficiary inducement prohibition in the Civil Monetary Penalty (CMP) Law to remove impediments to care...
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Recent DOJ and OIG Actions Show Growing Federal Scrutiny of Physician Financial Arrangements
By Daniel H. Melvin, Eric B. Gordon, MD, Jason B. Caron, Joan Polacheck and Tony Maida on Jul 1, 2015
Posted In Compliance Developments
Over the last month the Office of Inspector General (OIG) of the Department of Health and Human Services and the Department of Justice (DOJ) have each taken actions that suggest an increasing appetite to examine the financial relationships between physicians and recipients of those physicians’ referrals under the federal Anti-Kickback Statute (AKS). By announcing new...
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Court Upholds CMS’ Prohibition on ‘Under-Arrangements’ Transactions, Strikes Down CMS’ Prohibition on ‘Per-Click’ Equipment Rental Arrangements
By Daniel H. Melvin, Eric B. Gordon, MD, Jason B. Caron and Tony Maida on Jun 19, 2015
Posted In Stark
A 2008 rule change from the Centers for Medicare and Medicaid (CMS)—which effectively prohibited referring physician-owned companies from furnishing hospital services “under arrangements”—has withstood a challenge by a urology trade association. On June 12, 2015, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) held that the 2008 rule change, which...
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Fraud Enforcement Trends for 2015: Over the Horizon
By Ankur J. Goel, Daniel H. Melvin, Eric B. Gordon, MD, Jason B. Caron, Joan Polacheck, Laura McLane, Michael W. Peregrine, Tony Maida and T. Reed Stephens on Feb 18, 2015
Posted In Other Notable Enforcement Actions
Health care fraud enforcement continues to be a priority for the federal government and is poised to expand even more. As a result, health care providers and suppliers should anticipate greater oversight activities from auditors and investigators. Ensuring that your compliance program is up-to-date and up-to-task in proactively identifying problems and making timely decisions about...
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