HCCA 2016: Communicating with Regulators and Enforcement: Avoiding Pitfalls

Posted on
April 19, 2016

The Monday afternoon Communicating with Regulators and Enforcement: Avoiding Pitfalls session gave a glimpse into the mind of regulators and prosecutors.

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James J. Rough, Associate Director, Navigant Consulting, Inc
Cynthia Santana, Supervising Special Agent, Healthcare, Federal Bureau of Investigation, Las Vegas Office
Shaun Bowen, Deputy Chief Investigator, State of Nevada, Office of the Attorney General
Crane Pomerantz, Deputy Chief-White Collar Unit, Criminal Health Care Fraud Coordinator, US Attorney’s Office, District of Nevada

The Monday afternoon Communicating with Regulators and Enforcement: Avoiding Pitfalls session gave a glimpse into the mind of regulators and prosecutors. When evaluating whether or not to pursue a case there are a few elements to consider such as public safety risk, dollar amount in damages, and amount of information known, among many.

Cases can be approached as civil or criminal. There are two prongs to consider: the mistake that was made and the contributing intent. Regulators and prosecutors understand that medical billing and other topics are confusing and difficult, and they understand that mistakes happen. It’s the evaluation of the second prong, intent, which takes a case from a civil action to a criminal prosecution.

Our panel of speakers all agreed on the seriousness of their responsibility to bring bad actors to justice. To this end, governmental groups pursue open collaboration with each other as well as private entities to identify trends and align efforts to make our healthcare communities safer.

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