Complying With the New CMS Emergency Preparedness Rule for Medicare and Medicaid Providers and Suppliers

Similar documents
CMS Emergency Preparedness Rule

The CMS Rule and Healthcare Coalitions

Summary, January 8, 2013

Home Health Agency Requirements CMS Emergency Preparedness Final Rule

Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers

Hospital Emergency Preparedness Program Update

Retail Clinics in Healthcare: Overcoming Complex Legal Challenges

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

Hospital Emergency Preparedness Program Update

Agency for Health Care Administration

Hospital Emergency Preparedness Program Update

Clinics, Rehabilitation Agencies, and Public Health Agency Requirements CMS Emergency Preparedness Final Rule

May 25 th KCER CMS Emergency Preparedness Rule Training

Joint Commission Resources Quality & Safety Network (JCRQSN) Resource Guide. Centers for Medicare & Medicaid Services (CMS): Emergency Preparedness

Long Term Care Requirements CMS Emergency Preparedness Final Rule

AVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention

10 Government Contracting Trends To Watch This Year

Comprehensive Outpatient Rehabilitation Facility Requirements CMS Emergency Preparedness Final Rule

CMS: Ohio Society for Healthcare Facilities Management 2107 Annual conference. Randall Snelling 20 October 2017 BUSINESS ASSURANCE

Ambulatory Surgical Center Requirements CMS Emergency Preparedness Final Rule

Catastrophic Burn Injury Cases: Assessing Claims, Litigating, Negotiating Settlements

Telemedicine Privacy and Security: Safeguarding Protected Health Information and Minimizing Risks of Disclosure

Emergency Preparedness

Overview of the CMS Emergency Preparedness Final Rule

Hospital (and Transplant Center) Requirements as Written in the Final Rule

Programs of All-Inclusive Care for the Elderly Requirements CMS Emergency Preparedness Final Rule

Medical Staff Credentialing: Minimizing Liability Arising From Negligent Credentialing and Physician Lawsuits

Medicare s Electronic Health Records Incentive Program- Overview

ENFORCEMENT, COMPLIANCE, & LONG TERM CARE: HOME HEALTH, HOSPICE, & NURSING HOMES

AHLA Medicare & Medicaid Institute

A 12-Step Program to Better Compliance: A Practical Approach

Lee County Healthcare Coalition. December 7, PM Connie Bowles, RN MA CHECII Chair

Compliance Hotspots for CCBHCs

Holly Jo Bohannan, Esq., Associate General Counsel - East Region, LifeCare Health Partners, Plano, Texas

Hospital Outpatient Services: New CMS Supervision Requirements Complying With the New Rules to Protect Medicare Reimbursement

Before we begin. Summary on CMS rule for minimum Emergency Preparedness requirements

EMERGENCY PREPAREDNESS ACUTE CARE

San Francisco Department of Public Health

Responding to Today s Health Care Regulatory Environment

Emergency Management for Ambulatory Surgical Centers

The Department of Justice s Focus on Failure of Care Fraud Cases

Mary Massey, BSN, MA, CHEP California Hospital Association

Stark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare

Telemedicine Credentialing and Privileging

ASHE Resource: Implications of the CMS emergency preparedness rule

D ISASTER AND E MERGENCY P REPAREDNESS 101

HOT TOPICS IN HEALTHCARE FRAUD. Presented by: Jeffrey W. Dickstein and Amy L. Easton Phillips and Cohen LLP

Proposed Fraud & Abuse Rule Implementing ACA Provisions. Ivy Baer October 26, 2010

Highlights of Program Integrity Provisions Managed Care Delivery System Subcommittee June 9, 2011

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features:

COMPLIANCE GOTCHAS AND EMERGING RISKS

Compliance Program, Code of Conduct, and HIPAA

A Day in the Life of a Compliance Officer

Compliance Program Code of Conduct

CMS Ignored Congressional Intent in Implementing New Clinical Lab Payment System Under PAMA, ACLA Charges in Suit

Inpatient Hospital Services Billing, Denials and Reimbursement: Evolving Regulatory and Legal Landscape

Hospice House Network Inpatient Conference

Circular A-133 Audits for Non-Profits Receiving Grants Preparing for Audits and Protecting Grant Eligibility Given Current Government Priorities

Code of Conduct. at Stamford Hospital

TACKLING MEDICAL NECESSITY AND QUALITY ISSUES PRIOR TO DOJ, OIG, & CMS INTERVENTION

A Review of Current EMTALA and Florida Law

Prepublication Requirements

Emergency Preparedness Requirements

EMERGENCY PREPAREDNESS REQUIREMENTS Long Term Care Facility Overview

INLAND EMPIRE HEALTH PLAN CODE OF BUSINESS CONDUCT AND ETHICS. Our shared commitment to honesty, integrity, transparency and accountability

New York State Association of Medical Staff Services (NYSAMSS) Annual Education Conference

Public Health Preparedness for Health Centers:

Community Health Care And Emergency Preparedness. CNYRO HEPC Full Regional Meeting June 6, 2017

Healthcare Insolvencies: Navigating the Intersection of Medicare, ERISA, HIPAA, AKS, Stark and the Bankruptcy Code

Managing Business Relationships to Thrive and Comply

Compliance Program Updated August 2017

Diane Meyer, CHC (650) Agenda

Alignment. Alignment Healthcare

Specific Excerpts for Long Term Care Facilities (LTC) and Intermediate Care Facilities for Individuals with Intellectual Disabilities June 1, 2017

CAHABA GOVERNMENT BENEFIT ADMINISTRATORS (GBA) PROVIDER-BASED ATTESTATION STATEMENT. Main Provider Medicare Provider Number:

The Intersection of Compliance and Quality Health Care Compliance Association North Central Regional Annual Conference

Institute on Medicare and Medicaid Payment Issues. Baltimore Marriott Waterfront Hotel

Analysis. Tracking Referrals: When Does a Hospital s Review of Referral Source Information Pose Stark Law Risks?

WHAT TO EXPECT IF YOUR FACILITY RECEIVES A G LEVEL OR ABOVE DEFICIENCY

Audio Title: Revised and Clarified Place of Service (POS) Coding Instructions Audio Date: 6/3/2015 Run Time: 16:03 Minutes ICN:

CONDUCTING A COMPLIANCE REVIEW OF HOSPITAL- PHYSICIAN FINANCIAL ARRANGEMENTS

Centers for Medicare & Medicaid Services

Nursing Home Litigation and Admissibility of Evidence: Proving or Challenging Authentication, Relevance and Hearsay

CONTRACT YEAR 2011 MEDICARE ADVANTAGE PRIVATE FEE-FOR-SERVICE PLAN MODEL TERMS AND CONDITIONS OF PAYMENT

Audio is through computer speakers or select Phone on Audio Pane to call in. All attendees are muted.

Managed Care Fraud: Enforcement and Compliance HCCA Compliance Institute March 28, 2017

Part I of the HITECH Webinar Series

Preparing for the CMS Emergency Preparedness Rule Changes

Recover Health Training. Corporate Compliance Plan Code of Conduct Fraud & Abuse

Delegation Oversight 2016 Audit Tool Credentialing and Recredentialing

10/4/2017. New Home Health & Hospice Agencies. Missouri Deemed Agencies as of 10/02/2017. Agencies Currently Pending Deemed Status.

Medicare: "Complex regulatory structure."

Louisiana ESF8 Regional Training

CMS HOSPITAL CONDITIONS OF PARTICIPATION (COPS) 2011

Navigating the CMS Emergency Preparedness Final Rule

Life Care Planning: Beyond Estate Plans and Living Wills

Healthcare Coalition Tools to support CMS Emergency Preparedness Rule Compliance

Courtesy of Mark F. Weiss

Fraud, Abuse, & Waste, Oh My! Developing an Effective Compliance Program

CMS CoPs: New Emergency Preparedness Requirements

Transcription:

Presenting a live 90-minute webinar with interactive Q&A Complying With the New CMS Emergency Preparedness Rule for Medicare and Medicaid Providers and Suppliers Navigating Requirements for Risk Assessment, Communication, Training and More for Participation in Medicare and Medicaid WEDNESDAY, JANUARY 25, 2017 1pm Eastern 12pm Central 11am Mountain 10am Pacific Today s faculty features: Jackie Gatz, Vice President, Grant Management and Safety, Missouri Hospital Association, Jefferson City, Mo. Steven D. (Steve) Gravely, Partner, Troutman Sanders, Washington, D.C. Ted Lotchin, Partner, K&L Gates, Research Triangle Park, N.C. The audio portion of the conference may be accessed via the telephone or by using your computer's speakers. Please refer to the instructions emailed to registrants for additional information. If you have any questions, please contact Customer Service at 1-800-926-7926 ext. 10.

Tips for Optimal Quality FOR LIVE EVENT ONLY Sound Quality If you are listening via your computer speakers, please note that the quality of your sound will vary depending on the speed and quality of your internet connection. If the sound quality is not satisfactory, you may listen via the phone: dial 1-866-927-5568 and enter your PIN when prompted. Otherwise, please send us a chat or e-mail sound@straffordpub.com immediately so we can address the problem. If you dialed in and have any difficulties during the call, press *0 for assistance. Viewing Quality To maximize your screen, press the F11 key on your keyboard. To exit full screen, press the F11 key again.

Continuing Education Credits FOR LIVE EVENT ONLY In order for us to process your continuing education credit, you must confirm your participation in this webinar by completing and submitting the Attendance Affirmation/Evaluation after the webinar. A link to the Attendance Affirmation/Evaluation will be in the thank you email that you will receive immediately following the program. For additional information about continuing education, call us at 1-800-926-7926 ext. 35.

Program Materials FOR LIVE EVENT ONLY If you have not printed the conference materials for this program, please complete the following steps: Click on the ^ symbol next to Conference Materials in the middle of the lefthand column on your screen. Click on the tab labeled Handouts that appears, and there you will see a PDF of the slides for today's program. Double click on the PDF and a separate page will open. Print the slides by clicking on the printer icon.

Complying With the New CMS Emergency Preparedness Rule for Medicare and Medicaid Providers and Suppliers Jackie Gatz 5

Background and Purpose Challenges faced from natural and man-made disasters since 9/11 terrorist attacks. Definition of emergency or disaster : Event affecting the overall target population or the community at large that precipitates the declaration of a state of emergency at a local, state, regional, or national level by an authorized public official CMS reviewed a variety of emergency preparedness guidance from federal agencies, states, accrediting bodies and standard setting bodies. 6

Justification CMS also reviewed its existing EP regulations Conclusion: not comprehensive enough Doesn t address communication, coordination, contingency planning or training CMS concluded: Existing law, guidelines, accrediting organization EP standards, fall short of what is needed for healthcare to be adequately prepared for a disaster Thus, EP regulations intended to establish: a comprehensive, consistent, flexible, and dynamic regulatory approach to EP and response that incorporates the lessons learned from the past, combined with the proven best practices of the present. Regulations would encourage providers and suppliers to coordinate efforts in communities and across state lines. 7

Categories: Providers and Suppliers 1. Hospitals 2. Critical Access Hospitals (CAHs) 3. Rural Health Clinics (RHCs) & FQHCs 4. Long-Term Care Facilities (Skilled Nursing Facilities (SNF) 5. Home Health Agencies (HHAs) 6. Ambulatory Surgical Centers (ASCs) 7. Hospice 8. Inpatient Psychiatric Residential Treatment Facilities (PRTFs) 9. Programs of All-Inclusive Care for the Elderly (PACE) 10. Transplant Centers 11.Religious Nonmedical Health Care Institutions (RNHCIs) 12.Intermed. Care Facilities for Indiv. with Intellectual Disabilities (ICF/IID) 13.Clinics, Rehab. Agencies, & Public Health Agencies as Providers of Outpatient Physical Therapy & Speech Language Pathology Services 14.Comprehensive Outpatient Rehabilitation Facilities (CORFs) 15.Community Mental Health Centers (CMHCs) 16.Organ Procurement Organizations (OPOs) 17.End-Stage Renal Disease (ESRD) Facilities 8

The Role of Hospitals Hospitals are often the focal points for healthcare in their respective communities; thus it is essential that hospitals have the capacity to respond Medicare participating hospitals are required to evaluate and stabilize every patient see in the ED and evaluate every inpatient at discharge hospitals are in the best position to coordinate emergency preparedness planning with other providers and suppliers 9

CMS Emergency Preparedness Final Rule Timeline Proposed December 2013 Finalized September 8, 2016 Published in Federal Register on September 16, 2016 Effective November 16, 2016 Implement November 16, 2017 10

Noteworthy CMS received 400 public comments to the proposed rule. The proposed rule provided: detailed discussion of each requirement a methodology to establish and maintain preparedness resources and guidance available to organizations CMS encourages providers to reference the proposed rule, as needed. 11

Summary of Major Provisions 4 core elements to an effective and comprehensive framework. These provide framework for the rule for all provider/supplier categories. Risk assessment and planning Policies and procedures Communication plan Training and testing Emergency and standby power systems regulations only for inpatient providers (Hospitals, CAHs, LTC/SNFs) 12

Emergency Preparedness Plan and Program Risk Assessment Hospital risk assessment is based on and includes a documented, facility-based and community-based risk assessment, utilizing an all hazards approach. Emergency plan Emergency plan includes strategies for addressing emergency events identified by the risk assessment Patient population and available services The hospital emergency plan must address its patient population, including, but not limited to, persons at-risk. The hospital emergency plan must address the types of services that the hospital would be able to provide in an emergency. All hospitals include delegations add succession planning in their emergency plan to ensure that the lines of authority during emergency are clear and the plan is implemented promptly and appropriately. 13

Emergency Preparedness Plan and Program The hospital must have a process for cooperation and collaboration with local, tribal, regional, state, or federal emergency preparedness officials efforts to maintain an integrated response during a disaster or emergency situation, including documentation of the hospital s efforts to contact such officials and, when applicable, its participation in collaborative and cooperative planning efforts. allow a separately certified healthcare facility within a healthcare system to elect to be a part of the healthcare systems unified emergency preparedness program 14

Policies and Procedures Hospitals are required to develop and implement emergency preparedness policies and procedures based on the emergency plan, the risk assessment and the communication plan, reviewed and updated annually. Policies and procedures must address: Subsistence needs (staff and patients) System to track the location of staff and patients during an emergency if evacuated, document details of their relocation Ensure safe evacuation, transportation and placement A means to shelter in place for patients, staff and volunteers Systems of medical documentation to preserve, secure, and maintain availability of records Use of volunteers during an emergency, other emergency staffing strategies and the process to utilize state and federal resources Continuity of services arrangements with other hospitals and providers to receive patients, due to limitations or temporary closure the role of the hospital under an 1135 waiver, for the provision of care and treatment at an alternate care site 15

Communications Plan Hospital must develop, maintain and review annually an emergency preparedness communication plan that complies with federal, state and local law. Contact information for staff, entities providing services under arrangement, physicians, other hospitals and volunteers Government agency contact information for federal, state, tribal and/or local Establish primary and alternate communication Method for sharing information and medical documentation for patients with providers to maintain continuity of care Means, in the event of evacuation to release patient information, as permitted under 45 CFR 164.510(b)(1)(ii) Means to provide information about the general condition and location of patients under the facility s care. Means to provide information about occupancy, needs and ability to provide assistance 16

Training and Testing Hospital develop and maintain an emergency preparedness training and testing program that includes initial training based on hospital emergency plan, risk assessment, policies and procedures, and communication plan. hospitals provide such training to all new and existing staff, volunteers, consistent with their expected roles and maintain documentation of such training. Training on emergency procedures occur at least annually and demonstrate staff knowledge drills and exercises to test emergency plans participate in a full-scale exercise annually exemption if hospital experiences an actual incident conduct an annual exercise of hospitals choice for second requirement hospitals analyze their response to, and maintain documentation on all drills, tabletop exercises, and emergency events, and revise the hospital s emergency plan as needed. 17

Emergency Fuel and Generator Testing Hospitals must meet the requirements of NFPA 99 2012 edition, NFPA 101 2012 edition, and NFPA 110, 2010 edition 18

Contact Information Jaclyn E. Gatz, MPA Vice President of Grant Management and Safety Missouri Hospital Association jgatz@mhanet.com 573/893-3700 ext. 1330 19

Healthcare Providers and Disasters TROUTMAN SANDERS LLP Steve Gravely Partner Complying With the New CMS Emergency Preparedness Rule for Medicare and Medicaid Providers and Suppliers

Healthcare Providers and Disasters Healthcare is part of the nation s critical infrastructure per Homeland Security Presidential Directive 7 (2003) and Presidential Policy Directive 21 (2013) A resilient healthcare system is essential to effective disaster response Being prepared to respond to a variety of hazards is foundational to resiliency 21

The Current Healthcare Environment Disasters are inevitable The healthcare system is extremely vulnerable to disruption as we have seen from large scale events over the past 15 years Healthcare is high tech and high touch Today access to electronic medical records, cloud based services and wireless devices is essential to healthcare operations and these systems are fragile Requires highly qualified staff who cannot be replaced easily or rapidly 22

Recent Disasters Impacting Healthcare SARS Toronto 2003 Hurricane Katrina 2005 Superstorm Sandy 2012 Ebola 2014 23

Recent Disasters Impacting Healthcare SARS Virtually crippled the Toronto healthcare system Nurses were most affected, rampant staff shortages Work quarantine was invented and deployed Multiple government investigations, reorganizations, careers ended US was, miraculously, not affected Katrina Flooding of hospitals resulted in massive power failures and staff shortages Evacuation was chaotic and not coordinated Patients were separated from families Memorial Hospital is infamous for patient deaths One doctor was indicted but acquitted of murder 24

Recent Disasters Impacting Healthcare Superstorm Sandy Flooding led to large scale generator failures and power outages Patient evacuation was chaotic Remarkable that patient toll was not great Ebola Dallas hospital unprepared for Patient Zero Widespread panic spread rapidly Governors acted without coordination re quarantine of suspected nurses Staff refused to work due to fear of infection 25

Duty to Prepare There have been dozens of reports, studies, guidelines and recommendations which document that healthcare is vulnerable to disruption from natural and man-made events It is clear that hospitals have a duty to care for their patients which includes a safe environment and adequate resources Since disasters are easily foreseeable, healthcare providers have a duty to prepare for them Medicare CPs have the force and effect of law, so now all Medicare Participating Providers have a legal requirement to engage in disaster preparedness 26

Liability for Failure to Prepare Failure to comply can result in suspension or expulsion from Medicare program which is the death penalty for healthcare providers Medicare CPs as a standard of care? Provider agrees to comply with Conditions of Participation upon becoming certified by Medicare Yes, the CPs are mandatory standards and failure to comply could be evidence that a hospital failed to meet the standard of care If patients are injured, or worse, because of this noncompliance then a hospital could be held liable 27

Liability for Failure to Prepare There is no federal immunity for professional liability by nonfederal hospitals Some states have adopted special immunity statutes to protect healthcare providers during declared emergencies Liability for medical malpractice is capped in many states However, claims for negligent failure to prepare might not be med mal claims and not subject to caps There were multiple lawsuits filed post-katrina and post- SARS alleging negligent failure to prepare as a cause of action - these were not med mal cases 28

Liability for Failure to Prepare Healthcare is subject to many federal laws and regulations on just about every aspect of its operations including: Data privacy (HIPAA, HITECH, BREACH NOTIFICATION RULE) Treatment of all patients (EMTALA, Civil Rights, ADA, Obamacare) Control of medications (DEA) Environmental controls of biohazards (EPA) Billing for services (False Claims Act, False Statements Act, Civil Money Penalties Act) Financial arrangements with referral sources (Anti-Kickback Statute, Stark Law) Business structure and practices (IRS) Employment (EEOC, ADA, FLSA, FMLA) These federal laws are NOT automatically suspended during a disaster Even if the President declares a federal disaster under the Stafford Act, the HHS Secretary must issue specific 1135 waivers in order to suspend or modify these requirements 29

Liability for Failure to Prepare Katrina put this in the forefront Records were destroyed Patients were displaced Information was not shared that would have helped with reunification 11 years later during the Pulse shooting, Orlando hospitals were still not clear about what patient info they could share to help with reunification! Healthcare providers must assume that all federal and state laws and regulations remain in full force and effect during a disaster and find ways to continue operations in a compliant manner 30

Liability for Failure to Prepare Failure to comply with any of these federal laws can trigger administrative fines and penalties which can be substantial In the past, regulators have been tolerant of noncompliance during disasters Now that the CPs require that hospitals be prepared, will they be able to claim that their failure to comply is an extraordinary event? There are other risks, such as cyber, that we are only now beginning to wrestle with in the healthcare industry 31

Thank You Steve Gravely Troutman Sanders 401 9th Street, N. W. Suite 1000 Washington, D.C. 20004 202.274.2950 steven.gravely@troutmansanders.com 32

January 25, 2017 Living in a Material World - Emergency Preparedness Requirements for Medicare and Medicaid Providers and Suppliers Ted Lotchin K&L Gates LLP Copyright 2017 by K&L Gates LLP. All rights reserved.

Federal Civil False Claims Act

Federal Civil False Claims Act Prohibits a BROAD range of activities, including: Presenting a false or fraudulent claim for payment or approval Making, using, or causing to be made or used, a false record or statement MATERIAL to a false or fraudulent claim Making, using, or causing to be made or used, a false record or statement MATERIAL to an obligation to pay or transmit money or property to the Government "Knowingly" defined as: Having actual knowledge of the information; Acting in deliberate ignorance of the truth or falsity of the information; or Acting in reckless disregard of the truth or falsity of the information. "Material" means "having a natural tendency to influence, or be capable of influencing, the payment or receipt of money or property" klgates.com 35

Potentially Catastrophic Liability Penalties: Civil penalty between $10,781.40 and $21,562.80 (effective 8/1/16) per false claim, plus 3 times the amount of damages sustained by the Government Each item or service billed to Medicare or Medicaid is considered a claim, which means penalties accrue rapidly Qui Tam Provisions: Private individuals (or, relators) can file a lawsuit on behalf of the U.S. Whistleblower entitled to a percentage of any recoveries in the case Commonly include disgruntled employees, former investors, hospital executives, compliance officers, billing and administrative staff, patients, and/or competitors klgates.com 36

Significant Financial Recoveries $4.7 billion in FCA recoveries in 2016 $2.5 billion from health care industry 7 th straight year of recoveries over $2.0 billion from health care industry $31.3 billion in FCA recoveries since 2009 $19.3 billion from health care industry 30 qui tams filed in 1986 702 in 2016 $2.9 billion in qui tam recoveries related to qui tams in 2016 Government intervenes in roughly 20% of qui tam complaints Over 90% of cases in which government intervenes result in settlement or judgment against defendant Over 90% of declined qui tams are subsequently dismissed klgates.com 37

Implied False Certification

False or Fraudulent Claim Factual Falsity Claim is factually false on its face Billing for services that were never provided Upcoding and/or billing under incorrect CPT code Legal Falsity "Express Certification" typically refers to false representation of compliance with a federal statute, rule or regulation "Implied Certification" predicated on theory that the act of submitting a claim for reimbursement implicitly certifies compliance with relevant ancillary requirements klgates.com 39

Historical Circuit Split Seventh Circuit Only express or affirmative falsehoods can render a claim false or fraudulent The FCA is simply not the proper mechanism for government to enforce violations of conditions of participation contained in or incorporated by reference into a [program participation agreement]. Second Circuit Only non-compliance with a condition of payment "[I]mplied false certification is appropriately applied only when the underlying statute or regulation upon which the plaintiff relies expressly states the provider must comply in order to be paid." klgates.com 40

Historical Circuit Split First Circuit Include conditions of participation, quality standards, and contract provisions that are material to payment decision Rejected argument that claim can only be false or fraudulent if it fails to comply with a precondition of payment expressly identified in statute or regulation. "[C]onditions of payment need not be expressly designated as such to be a basis for [FCA] liability." Precondition of payment need not be found in a statute or regulation. klgates.com 41

UHS v. U.S. ex rel. Escobar Recent Supreme Court opinion resolved circuit split and provided guidance on materiality requirement Teenage Medicaid beneficiary received counseling and medication management services at mental health facility Experienced seizures in response to medication prescribed to treat bipolar disorder and ultimately died State investigation determined that very few counselors providing services were actually licensed and/or supervised appropriately Regardless, facility billed for individual and family therapy as if provided by licensed clinical social workers Beneficiary's parents alleged that facility provided inadequate care by using underqualified and unsupervised personnel to deliver services Argued facility "impliedly certified" services were provided by specific types of professionals in accordance with state Medicaid requirements klgates.com 42

Validates Implied Certification False or fraudulent claims include more than just claims containing express falsehoods Every claim for payment implicitly certifies compliance; OR Nondisclosure of legal violations absent some special duty Theory upheld where: Claim for payment makes specific representations about goods or services provided; AND Failure to disclose non-compliance with material statutory, regulatory, or contractual requirements makes those representations misleading klgates.com 43

Only Material Non-Compliance Misrepresentation about compliance with a statutory, regulatory, or contractual requirement must be MATERIAL to the Government's payment decision Reaffirms that material means "having a natural tendency to influence, or be capable of influencing, the payment or receipt of money or property" Materiality under any standard look[s] to the effect on the likely or actual behavior of the recipient of the alleged misrepresentation. klgates.com 44

Demanding Materiality Does not depend on whether requirement is labeled a condition of payment relevant not dispositive Cannot be found where non-compliance is minor or insubstantial Government consistently refuses to pay claims based on non-compliance with statutory, regulatory, or contractual provision Government pays claim in full despite actual knowledge of non-compliance with statutory, regulatory, or contractual provision klgates.com 45

A Glimmer of Hope Rigorous materiality standard FCA is not a means of "imposing treble damages and other penalties for insignificant regulatory or contractual violations" "This case centers on allegations of fraud, not medical malpractice." FCA is not an all-purpose antifraud statute klgates.com 46

Living in a Material World Post-Escobar, courts are being asked to define which requirements are material to a payment decision At least six federal courts of appeal and 20+ district courts have decided Escobar-related motions End of bright line distinction for conditions of payment and participation means more stringent pleading requirements Materiality requirement is both rigorous and demanding, and must be pled with particularity Conclusory statements will not be sufficient klgates.com 47

Living in a Material World First Circuit U.S. ex rel. Escobar v. UHS [C]ourts are to conduct a holistic approach to determining materiality in connection with a payment decision, with no one factor being necessarily dispositive. Licensing and supervision requirements go to the "very essence of MassHealth s contractual relationships with various healthcare providers under the Medicaid program Seventh Circuit U.S. v. Sanford Brown, Ltd. Department of Education reviewed for-profit college s compliance with Higher Education Act and did not pursue administrative penalties or program termination Establishing that non-compliance would have entitled the government to decline payment will not meet materiality standard klgates.com 48

Living in a Material World Eighth Circuit U.S. ex rel. Miller v. Weston Educational False statement is material if (1) a reasonable person would likely attach importance to it; OR (2) defendant knew or should have known that government would attach importance to it. Materiality depends on whether for-profit college s promise to maintain accurate grade and attendance records influenced the government's decision to enter into its relationship with the college. klgates.com 49

Living in a Material World E.D. Va. U.S. ex rel. Beauchamp v. Academi Training Centers, Inc. [S]trains credulity to argue that payment decision would not have been affected if the government knew that private security contractors had not fulfilled weapons training requirements N.D. Cal. Rose v. Stephens Institute Compliance with federal law that prohibits colleges from providing incentive compensation to college recruiters is material to government s payment decision Department of Education s decision not to take action against college despite its awareness of allegations of non-compliance not terribly relevant to materiality klgates.com 50

Living in a Material World S.D. Ala. U.S. v. Crumb Falsified diagnoses to ensure reimbursement for botox and other cosmetic procedures material to payment decisions E.D. N.Y. U.S. ex rel. Lee v. Northern Adult Daily Health Care Center Failed to allege that discriminatory treatment of residents in violation of Title VI of the Civil Rights Act and Department of Housing regulations would have influenced payment decision D.D.C. U.S. v. Dynamic Visions Compliance with plan of care requirements for home health services material to D.C. Medicaid s payment decision klgates.com 51

Emergency Preparedness

Legacy Conditions of Participation Historically, limited potential for liability created by noncompliance with emergency preparedness requirements N.D. N.Y. U.S. ex rel. Blundell v. Dialysis Clinic, Inc. Claims included failure to adequately train employees on emergency preparedness Analyzed under the majority view that required non-compliance with conditions of payment Complaint dismissed because allegations only involved conditions of participation No indication that emergency preparedness requirements would be material to government s payment decision klgates.com 53

New Conditions of Participation Four core elements to an effective and comprehensive framework Risk assessment and planning Policies and procedures Communication plan Training and testing Question Will non-compliance with any of these elements be material to government payment decisions? klgates.com 54

Potential Arguments for Materiality Holistic approach - Emergency preparedness requirements go to the very essence of the bargain with participating providers Preamble puts providers on notice that government will attach importance to emergency preparedness requirements In light of recent mass casualty events and public health emergencies, strains credulity to believe that government payment decisions would not be affected klgates.com 55

Potential Arguments Against Materiality FCA is not an all-purpose antifraud statute Condition of participation, not payment Non-compliance is minor or insubstantial Government pays for provider services despite actual knowledge of non-compliance with emergency preparedness COPs Non-compliance would only have entitled government to decline payment for services klgates.com 56

Case Study - Cybersecurity

Cyberattacks in the Health Care Industry Hacker collective Anonymous targets Boston Children s Hospital (2014) Fourteen hospitals attacked with ransomware (2016) OIG report on hospital contingency planning for EHR disruption (2016) Cyberattacks responsible for roughly 30% of all major HIPAA breaches (2016) klgates.com 58

All-Hazards Emergency Planning Integrated approach to planning that focuses on critical capacities and capabilities for a full spectrum of emergencies or disasters. Specific to the location of the provider or supplier Considers the particular types of hazards most likely to occur Risk assessment and emergency planning can include processes to account for cyberattacks klgates.com 59

New Theories of Liability Duty to prepare? Liability for failure to prepare? Implied false certification? Material to government s payment decision? Minor or insignificant non-compliance? Essence of contractual obligations? Increased government enforcement puts providers on notice? klgates.com 60

61 Ted Lotchin Partner K&L Gates LLP Research Triangle Park (919) 466-1240 Ted.Lotchin@klgates.com