In Treatment: Physicians and the Professionals Resource Network (PRN)

In an industry so concerned with serving others, physicians and other health professionals sometimes find that they are the ones being pushed towards a treatment program. According to a recent study, alcohol abuse is the most common reason for enrolling in a physician health program. Other reasons for treatment included opioid, stimulant and sedative abuse. However, not all physicians and health professionals that are referred to a health program are in need of rehabilitation services.

The Florida Department of Health’s Impaired Practitioners Program is administered by the Professionals Resource Network (PRN) and the Intervention Project for Nurses (IPN). IPN is responsible for all nurses and works with and through the Florida Board of Nursing. The Florida Board of Medicine and all other professional licensing boards in the DOH have contracted with and use the services provided by Professionals Resource Network (PRN).

We routinely work with physicians who are accused by employers, hospitals, competitors, terminated employees, or supervisors in graduate medical education (GME) programs of impairment due to drug or alcohol abuse, of mental impairment, of being a “disruptive physician” or of sexual boundary issues.

Our firm has extensive experience in representing physicians and other professionals accused of drug abuse, alcohol impairment, mental impairment and sexual boundary issue, as well as in dealing with the Professionals Resource Network (PRN), its advantages and disadvantages, its contracts, its personnel, and its policies and procedures.

We are also quite familiar with the interactions between PRN and the Board of Medicine. We have had a great deal of experience in working with the different psychiatrists, certified addictions professionals (CAPs) and evaluators which PRN routinely employs to perform its initial evaluations on physicians.

Our clients routinely include physicians and other health professionals who are alleged to be impaired because of drug abuse, alcohol abuse or mental or physical impairments. We routinely are consulted by physicians who have a DUI conviction, who have a positive result on a drug or alcohol test or who are accused of addiction or theft of drugs because of discrepancies in drug inventories, or for any other number of reasons.

We routinely consult with, advise and defend physicians facing all of the foregoing types of problems. It is crucial that the physician obtain qualified legal representation and advice immediately before speaking to hospital administrators or medical staff leaders about the matter, before giving a urinalysis sample, before reporting to PRN and before going for an evaluation by a psychiatrist or a certified addictions professional (CAP).

Furthermore, these types of allegations made against a physician are extremely serious because they are usually treated by the Department of Health as “Priority 1” or “Fast Track” offenses. This means that the charges against the physician will usually be automatically considered for an Emergency Suspension Order (ESO) by the Department of Health. The investigation will be “fast and dirty” with a requirement that the DOH investigator have the entire investigation completed and the report in Tallahassee within 45 days. Then, unless a qualified, experienced attorney is able to immediately produce reliable documentation and other evidence showing the physician is not impaired and is not a threat to patient health or safety, the Surgeon General (formerly the Secretary of the Department of Health) will issue an Emergency Suspension Order (ESO). This suspends the physician’s license until all proceedings are completed and finalized (which often takes a year or more). The physician will be unable to work as a physician during any period when his or her license is suspended and, even if he or she has a license in another jurisdiction, since the suspension is a public record that is widely published and other jurisdictions are notified, he or she may find the license in the other states is also suspended.

However, even where the physician may actually have committed the offense, there are a number of administrative and procedural measures which an experienced health care attorney, one familiar with Board of Medicine and PRN cases, may be able to use to avoid a suspension. This will also prevent the matter from becoming public until much later in the process.

For the innocent physician or health professional, an experienced attorney familiar with such matters may be able to obtain additional drug testing, polygraph (lie detector) testing, scientific evidence, expert witnesses, evaluations by certified addictions professionals, character references, or other evidence which shows innocence.

PRN does have some advantages for the truly impaired physician. It provides an avenue of rehabilitation, monitoring and treatment for a truly impaired physician. It is an invaluable tool to assist a physician with a real problem to retain his ability to practice. Some physicians should not be practicing except through PRN. However, PRN also has some serious disadvantages and may, among other things, cause the physician to lose clinical privileges in a hospital; lose an employment position; require the physician to enter into long term inpatient rehabilitation; cause the physician to undertake extremely expensive treatment counseling and therapy; and impose very onerous burdens of time and money on the physician, as well as job limitations. Additionally, PRN routinely relies on Alcoholics Anonymous (AA) and its particular philosophy of coping with substance abuse, even though there may be competing schools of thought on the subject, some of which are equally or more effective.

In many cases, the physician who is the victim of a termination action by an employer, a complaint by a hospital or a complaint against his or her professional license involving allegations of drug abuse, alcohol abuse, or impairment, may view PRN as an easy way to avoid discipline. This is a complete fallacy. Such an apparent easy way out should be avoided at all costs.

If the physician is not truly an impaired provider or addicted to drugs or alcohol, there may be other alternatives that do not involve discipline. PRN is not “easy” and this is not an easy way out.

It is extremely important that before you “self-report” to PRN you contact an experienced health care attorney for advice.
If the physician is not truly an impaired provider or addicted to drugs or alcohol, there may be other alternatives that do not involve discipline.

It is extremely important that before you agree to go to the initial evaluation by a physician (or sometimes a psychologist or mental health counselor) specializing in addictionology (as PRN always requires), obtain legal advice.

Before you give any blood, urine, hair samples or other drug or alcohol testing, you should contact us for advice. We have access to the same or similar testing labs as PRN. We can arrange to have you tested first so that you will know whether or not you should have any concerns. For example, did you know that the use of certain prohibited drugs (including cocaine) will leave a residue in your hair which can be detected for months or longer after use? Are you aware that there are now tests being used which can tell if you have had one regular size alcoholic beverage within the past thirty (30) days? There are even tests being used now to test health care professionals for the illicit use of anesthetic gases such as Aldan.

We are consulted by just as many physicians who want to get out of the PRN Program after they agreed to enter it without proper legal advice. Even though at the time it seemed like a good idea, or the physician incorrectly thought there was no choice in the matter, it turns out to be a big mistake for that person. In most cases, it is not possible to leave the PRN Program after agreeing to it without giving up your medical license. And this can have some extremely adverse consequences for a physician, including a report to the National Practitioner Data Bank (NPDB), exclusion from the Medicare and Medicaid Programs and debarment from all federal government contracting.

We are told that 60 day, 90 day, and longer periods of inpatient drug or alcohol treatment may be required before the physician can return to work. Physicians accepted into PRN usually must sign a five year contract agreeing to monitoring, weekly counseling meetings, regular psychiatric visits, random urinalysis testing (with a mandatory call in every day of your life for the five year contract period), mandatory notification of all employers and hospitals where you have clinical privileges that you are in PRN, a strict prohibition on drinking any alcoholic beverage or taking any medication (even over the counter medications) without the prior approval of PRN, possible loss of your privilege to prescribe or administer narcotics, a possible requirement that you only work under the supervision of another physician, or other possible requirements.

The bottom line is: If you are accused of drug impairment, alcohol impairment, sexual boundary issues, sexual misconduct, or of being mentally or physically impaired, immediately contact an attorney experienced with PRN and Board of Medicine matters before doing anything else. Don’t risk losing your livelihood by taking the apparent only way out. There may be other options available for you. For more information about PRN and other legal matters concerning health professionals, visit www.TheHealthLawFirm.com.

Medical Negligence – An Accidental Overdose of Prescription Pain Pills Can Lead to Lawsuits

GFI Blog LabelBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law and Carole C. Schriefer, R.N., J.D., The Health Law Firm

In February 2009, a 30-year-old male patient was prescribed, all together, 180 pills of Dilaudid and Xanax from a South Florida pain clinic. Sometime within the next 24 hours the patient died of what medical examiners ruled an overdose. According to the American Association for Justice, the patient’s family then sued the pain management clinic alleging the clinic’s physician prescribed a lethal overdose of the drugs and the defendant was liable for damages resulting from the patient’s murder. In the lawsuit, the jury awarded the plaintiff more than $5.33 million.

Physicians and Business Owners Liable for Medical Negligence.

According to an article in American Medical News, of the pharmaceutical-related overdoses in 2010, seventy-four percent (74%) were unintentional. As prescription drug overdoses rise across the country, we are seeing some physicians and business owners held liable for medical negligence.

For example, in May 2012, an Alabama jury ruled a widower to receive $500,000 after he sued his wife’s physician. His wife died of an accidental overdose after being prescribed a number of narcotic pain medications. In April 2012, a woman was awarded $1.9 million after she sued her family physician claiming he over prescribed her methadone, which led to brain damage after she stopped breathing, according to American Medical News.

Click here to read the entire article from American Medical News.

Protecting Your Business and License.

Health care professionals need to pay close attention to patients who request pain medication. Being proactive about prescription management can also deter lawsuits or help in doctors’ defense if they are sued. Physicians must make sure their records meet all requirements of state laws and regulations. In cases where a patient has been “doctor-shopping” in order to abuse pain pills, we see state disciplinary investigations initiated against each physician who prescribed that individual medication. In most cases, these physicians were unaware of the other prescribers. Disciplinary actions such as these can often be defended when the physician has taken the proper safeguards.

Click here to read legal tips for physicians to manage pain patients.

Drug Monitoring Programs are Here to Stay.

The growing epidemic has some states developing drug monitoring programs to track drug seekers.

In Florida, a bill that would require doctors to check with the state’s drug database before writing a prescription for addictive medications passed in a House panel on March 19, 2013. Recently, legislators in California, Pennsylvania and Kentucky are contemplating moves to tighten monitoring and prescribing of controlled substances. Click here to read a blog on the possible new actions in these states.

Health professionals should take note, these prescription drug monitoring programs can, and will be, used as a prosecution tool.

Contact Health Law Attorneys Experienced with Investigations of Health Professionals and Providers.

The attorneys of The Health Law Firm provide legal representation to physicians, nurses, nurse practitioners, CRNAs, pain management doctors, dentists, pharmacists, psychologists and other health providers in Department of Health (DOH) investigations, Drug Enforcement Administration (DEA) investigations, FBI investigations, Medicare investigations, Medicaid investigations and other types of investigations of health professionals and providers.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Comments?

Do you think physicians and business owners should be held liable for medical negligence in cases of an accidental overdose? Please leave any thoughtful comments below.

Sources:

Department of Justice. “Thirty-Two Indicted in Broward and Palm Beach Counties in Second Coordinated Pill Mill Takedown.” Department of Justice. (August 23, 2011). From: http://www.justice.gov/usao/fls/PressReleases/110823-04.html

Gallegos, Alicia. “Physician Liability: When an Overdose Brings a Lawsuit.” American Medical News. (March 4, 2013). From: http://www.thehealthlawfirm.com/uploads/AMN_Overdose%20Lawsuits.PDF

LaMendola, Bob. “Pain Clinic Boss Jeffrey George Pleads Guilty to Murder.” Sun Sentinel. (August 29, 2011). From: http://articles.sun-sentinel.com/2011-08-29/health/fl-hk-jeff-george-pleads-guilty-20110829_1_pain-clinic-cynthia-cadet-george-twins

About the Authors: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

Carole C. Schriefer is an attorney with The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Avenue, Altamonte Springs, Florida 32714, Phone: (407) 331-6620.

 

The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Florida’s Strike Force Raids Pain Management Physicians

Florida is reported to have one of the worst prescription drug abuse problems in the country. Because of this issue, pain management physicians have been under increasing scrutiny and attack by federal and state agencies.  If you are a pain management physician or you work in a pain a management clinic, you need to be aware of the measures that state and federal agencies are taking against doctors who practice pain management and the owners of pain management clinics.

A news release sent out by the Florida Department of Health (DOH) this summer discusses “inspections” of physicians’ offices across the state, allegedly to ensure compliance with Florida’s new prescription drug law (House Bill 7095).  However, many of these may be more aptly termed as “raids.”  These raids, under the guise of being inspections, have resulted in a massive quantity of narcotics being seized from clinics and physicians’ offices by the Strike Force. It is claimed that no search warrants are necessary as the Strike Force states it is performing an “administrative inspection.” The pain management physicians targeted by these inspections are identified based on their purchasing, prescribing and dispensing levels.

Often these “inspections” will include Department of Health Investigators, Florida Department of Law Enforcement Special Agents, local police and law enforcement agents, and Drug Enforcement Administration (DEA) Special Agents.

  •  Our primary concern and warning to the physician or owner is to not talk to any investigators or inspectors, but call your personal attorney immediately. Have the investigator or inspector talk to your attorney. All communications should be with and through your attorney.
  • If you are requested to “voluntarily” relinquish (give up) your DEA registration or your medical license or other professional license, do not do this.  It will not help you and it will make every aspect of your case more difficult to defend.
  • Do not make any statement (oral or written) or allow yourself to be interviewed.
  • Obtain the complete names, addresses, titles and agencies for each agent there.  Obtain their business cards (which they should have).
  • Do not volunteer up any documents, items or information.

To read more about inspections from the document released by the Florida Department of Health click here.

If your office has been “inspected” and you need legal representation, you may call and speak to one of our health attorneys at (407) 331-6620 or (850) 439-1001.

Number of Oxycodone-Related Deaths Down in Florida

1 Indest-2008-1By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

It looks like Florida’s prescription drug legislation, the statewide prescription drug monitoring database and the prescription drug crackdowns by law enforcement may be working, according to the Florida Department of Law Enforcement (FDLE). The FDLE states in its semi-annual report, oxycodone-related deaths statewide dropped between January and June of 2012, compared to the same period of time in 2011. A look at the national numbers shows that the number of people abusing prescription drugs is also down.

Florida and National Numbers.

In the first half of 2012, there were 759 oxycodone-related deaths in Florida, according to the Orlando Sentinel. That number is down from 1,058 during the same time period a year before. The Orlando Sentinel states that nationwide 7 million people abused prescription drugs in 2010. By 2011, that number had dropped to 6.1 million. Studies also show prescription drug use among young adults ages 18 to 25 is also on the decline. The Metropolitan Bureau of Investigation Director believes these numbers are down because young people are realizing these drugs are dangerous and can be deadly.

Click here to read the entire article from the Orlando Sentinel.

Florida Cracks Down on Prescription Drug Abuse.

Previously, Florida was known as a state where drug addicts and dealers could easily find a pill mill or go doctor shopping to get prescription drugs. In the past two years, Florida state leaders and law enforcement officials have stepped up regulations and made serious crackdowns on doctors, pharmacists and pharmacies.

In April 2013, a Lake Mary doctor was sentenced to 25 years in prison for trafficking prescription drugs. Click here to read that story. In December 2012, a fake prescription drug ring was busted in Osceola County. To read that story, click here. In June 2012, the Drug Enforcement Administration (DEA) and Florida law enforcement announced operation “Pill Street Blues” targeting doctors and clinic owners across Florida. Click here to read more.

Health Care Professional Must Stay Ahead of Patients with Chronic Pain.

Even though the number of people abusing prescription drugs is down, state regulatory boards, private certification boards and federal agencies are not going to ease up. Many physicians in practice today are eschewing multi-disciplinary approaches to treating chronic pain in favor of monotherapies with narcotic medications.

These physicians do this at their own peril. In our practice we see many physicians in trouble with state medical boards and law enforcement officials because of their prescribing practices. If you treat patients with chronic pain it is imperative that you stay ahead of them. Click here to read a blog on legal tips for health care professionals to manage pain patients.

Contact Health Law Attorneys Experienced with Investigations of Health Professionals and Providers.

The attorneys of The Health Law Firm provide legal representation to physicians, nurses, nurse practitioners, CRNAs, pain management doctors, dentists, pharmacists, psychologists and other health providers in Department of Health (DOH) investigations, Drug Enforcement Administration (DEA) investigations, FBI investigations, Medicare investigations, Medicaid investigations and other types of investigations of health professionals and providers.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Comments?

Do you think the new legislation, the state prescription drug monitoring database and the crackdowns by law enforcement are making a difference in the war against prescription drugs? Please leave any thoughtful comments below.

Sources:

Pavuk, Amy. “‘We Can Stop This Epidemic,’ CDC Boss Says at Rx-Drug Abuse Summit in Orlando.” Orlando Sentinel. (April 2, 2013). From: http://www.orlandosentinel.com/news/local/breakingnews/os-prescription-drug-abuse-summit-20130402,0,4693169.story

Pavuk, Amy. “Drug-Related Deaths Plunge in First Half of 2012.” Orlando Sentinel. (March 25, 2013). From: http://www.orlandosentinel.com/news/local/breakingnews/os-drug-deaths-down-20130325,0,6750345.story

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.

Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Orlando Health Attorney Featured in Latest Issue of Medical Economics

Orlando, Fla. – March 15, 2012 – George F. Indest III, President and Managing Partner of The Health Law Firm, shares his knowledge of health law in the March 14 issue of Medical Economics. Mr. Indest was interviewed and quoted for an article concerning legal advice for primary care physicians who prescribe painkillers. In the article he provided information based on his experience in defending physicians charged with over-prescribing with the DEA and Florida DOH, Board of Medicine.

The article, “5 ways to avoid over-prescribing allegations,” includes tips written by Mr. Indest for physicians to follow if they practice pain management. The article can be read in its entirety here.

Mr. Indest is a well-known attorney specializing in the representation of health professionals and health care providers throughout Florida. His practice encompasses all aspects of health law, including pain management and pain medicine physician and clinic defense, defense of professional licensing cases, representation in investigations, defense in credentialing matters, Medicare and Medicaid audits, formation of corporations and limited liability companies (LLCs), Board of Medicine hearings, peer review actions, clinical privileges hearings, representation of medical students, and other matters of health care law and legal representation of health care professionals.

In 1999, Mr. Indest started The Health Law Firm, which has three Florida offices in Altamonte Springs, Orlando, and Pensacola. A former Navy JAG Corps attorney, he has practiced law for over 30 years.

For more information about The Health Law Firm visit http://www.thehealthlawfirm.com.

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About The Health Law Firm
The Health Law Firm was established in 1999, bringing together a team of experienced attorneys with decades of work in the legal and healthcare fields. With offices in Altamonte Springs, Orlando and Pensacola, Florida, the firm represents healthcare providers, including hospitals, nursing homes, physicians, dentists, mental health professionals and other licensed health professionals and entities. For more information about The Health Law Firm, visit http://www.thehealthlawfirm.com.

For additional information contact:
Kara Large
Office: (407) 331-6620, ext. 219
Cell: (407) 921-4322

Strike Force Busts 89 People, Mostly Health Care Professionals, in Nationwide Crackdown on Medicare Fraud

8 Indest-2008-5By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

In a nationwide takedown nearly 100 people, including doctors, nurses and other medical professionals, in eight cities were all allegedly charged in separate Medicare fraud schemes. These individual scams involved approximately $223 million in false billing, according to the Department of Justice (DOJ) and the Department of Health and Humans Services (DHHS). On May 14, 2013, more than 400 law enforcement officials with the Medicare Fraud Strike Force spread out between Miami, Detroit, Los Angeles, New York, New Orleans, Houston, Chicago and Tampa to make the arrests of these 89 people, according to the DOJ.

Click here to read the press release from the DOJ.

Medicare Schemes Could Not Have Happened Without the Help of Health Professionals.

According to an article in Reuters, one out of every four defendants in this crackdown was some type of health professional. Authorities say most of these allegedly complex scams could not have happened without the participation of a doctor signing off on a bogus service, or a nurse filling out false paperwork.

Click here to read the entire article from Reuters.

Florida Health Professionals Involved.

According to the DOJ, in Miami, a total of 25 people, including two nurses and a paramedic, were allegedly part of numerous Medicare scams, totaling about $44 million in false claims. In one case involving a home health agency, defendants allegedly bribed Medicare beneficiaries for their Medicare information, which was used to bill for home health services that were never rendered or not medically necessary. The DOJ believes the lead defendant spent a majority of the money from the scam on luxury cars.

Phony Health Care Clinics Set Up.

In Tampa, nine individuals were charged in a variety of schemes, ranging from pharmacy fraud to health-care related money laundering. According to the DOJ, in one case four individuals allegedly established four health care clinics. The individuals allegedly used these clinics to steal more than $2.5 million from Medicare for surgical procedures that were never performed.

This Marks the Sixth Time the Medicare Fraud Strike Force Has Executed a Nationwide Crackdown.

This crackdown marks the sixth time the Medicare Fraud Strike Force has taken nationwide action against Medicare fraud. To date, the Medicare Fraud Strike Force is credited with making more than 1,500 arrests on charges related to $5 billion in allegedly false Medicare claims since 2007. According to the DOJ, it’s believed Medicare fraud costs the program between $60 billion and $90 billion each year.

Medicare operates under a pay-and-chase system, but according to the Washington Post, authorities are beginning to use new technology that flags suspicious claims before Medicare makes a payment. To read the entire Washington Post article, click here.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent health care providers in Medicare audits, ZPIC audits and RAC audits throughout Florida and across the U.S. They also represent physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Comments?

What do you think of these nationwide crackdowns on Medicare fraud? Do you think they work as a deterrent for others committing health care fraud? Please leave any thoughtful comments below.

Sources:

Department of Justice. “Medicare Strike Force Charges 89 Individuals for Approximately $223 Million in False Billing.” Department of Justice. (May 14, 2013). From: http://www.justice.gov/opa/pr/2013/May/13-crm-553.html

Kennedy, Kelli. “Doctors and Nurses Among Nearly 100 Charged in $223 Million Medicare Fraud Busts in 8 Cities.” Washington Post. (May 14, 2013). From: http://www.washingtonpost.com/politics/health_care/doctors-nurses-among-nearly-100-charged-in-223-million-medicare-fraud-busts-in-8-cities/2013/05/14/fbb0de3a-bcbc-11e2-b537-ab47f0325f7c_story.html

Morgan, David. “U.S. Charges 89 People in $223 Million Medicare Fraud Scheme.” Reuters. (May 14, 2013). From: http://www.reuters.com/article/2013/05/14/usa-healthcare-fraud-idUSL2N0DV3GZ20130514

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

 

The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2012 The Health Law Firm. All rights reserved.

2010 District Ruling for $44.9 Million in Tuomey Overturned by U.S. Appeals Court

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

Tuomey Reversed

The 4th U.S. Circuit Court of Appeals overturned a federal district judge’s 2010 decision for Tuomey Healthcare System on March 30, 2012. (U.S. ex rel. Drakeford v. Tuomey Health. Sys., Inc., 4th Cir., No. 10-1819 (Mar. 30, 2012)) The lower court’s decision ordered Toumey Healthcare System to pay $44.9 million for allegedly violating the Stark Law. (42 U.S.C. § 1395nn) The appeals court decided that the 2010 district ruling denied Tuomey its Seventh Amendment right to a jury trial. 

A physician initiated a qui tam or whistle-blower suit against Toumey under the False Claims Act in 2005. The suit was later picked up and prosecuted by the U.S. Department of Justice. In the False Claims Act complaints filed in the U.S. District Court in Columbia, S.C., the whistle-blower and the U.S. Department of Justice (DOJ) alleged that Tuomey had contracts with physicians that were illegally overpaid by Tuomey. This was alleged to be in exchange for their exclusively referring patients to Tuomey’s hospital, thus violating the Stark Law. Billings for referrals from those physicians allegedly constituted false claims as a result of this.

Novel Theory Used to Obtain Large Recovery

This was a novel theory to pursue in a qui tam or whistle-blower case because it was not based directly on submission of false claims. Instead it put forth the theory that the claims were false because they violated the anti-referral provisions of the Stark Act.

In March 2010, a jury found that Tuomey had not violated the False Claims Act but did find Tuomey guilty of committing Stark Law violations. (Note: The Stark Act does not establish a private cause of action for plaintiff to recover civil damages.) This jury verdict was set aside by the judge and a new trial regarding the False Claims Act allegations was granted. Under the lower court’s decision, Tuomey was still required to repay the government $44.9 million in Medicare payments that were allegedly received through physician contracts that violated the Stark Law.  This was the part of the verdict that was not set aside by the trial court.

However, according to the opinion of the appeals court, when the district court set aside the jury’s verdict, it specifically ordered that the new trial would encompass the whole False Claims Act matter, including whether Tuomey had violated the Stark Law. This nullified the jury’s interrogatory answer (part of the verdict it returned) regarding the Stark Law. Thus, when the district court ordered Tuomey to repay the government for violating the Stark Law, it denied Tuomey of its right to a jury trial.

Two Major Stark Issues Discussed

The appeals court also addressed two major Stark Law issues that were raised on appeal and are likely to recur on remand. The first issue is whether the facility component of the services performed by the physicians, for which Tuomey billed a facility fee to Medicare, constituted a “referral” within the meaning of the Stark Law. The court used the Health Care Financing Administration’s (now the Centers for Medicare and Medicaid Services) final rule on referrals (66 Fed. Reg. 856, 941, Jan. 4, 2001) to conclude that the facility/technical component of the physician’s personally performed services does constitute a referral.

The second issue was the correct standard to use. Having decided that the physicians were making referrals to Tuomey, the appeals court then examined if an arrangement that takes into account anticipated referrals violate the Stark Act’s “volume or value standards.” The “volume or value standards” require that compensation must be calculated in a way that does not take into account the volume or value of referrals between the parties.

Fair Market Value Standard

Additionally, Stark Act requires that whatever financial relationship exists reflects “fair market value.” Stark defines “fair market value” as compensation that “has not been determined in any manner that takes into account the volume or value of anticipated or actual referrals”(42 C.F.R. § 411.351). Thus, the court concluded that compensation based on the volume or value of anticipated referrals does implicate the volume or value standard. The court left it to the jury to decide if Tuomey’s contracts violated the fair market value standard.

$50 Million May be Returned to Tuomey

The government has 45 days from the date of the decision to request a rehearing. If it doesn’t, the matter goes back to the South Carolina federal district court where it was originally decided. Tuomey can then request the money that it had set aside to pay the government back, $50 million according to it, to be released to the health system.

Tuomey Issues Press Release

In a press release dated March 31, 2012 (Press Release), signed by Jay Cox, its President and Chief Executive Officer (CEO), Tuomey Healthcare System stated:

The 4th Circuit has issued an opinion in favor of Tuomey on our appeal. We are pleased that the 4th Circuit Court has decided that the District Court’s judgment violated Tuomey’s Seventh Amendment right to a jury trial, and vacated (reversed) the $50 million judgment against Tuomey Healthcare System.

*          *          *

As the Court of Appeals said in the opinion: “The whole case, including the issues of fact at the former trial is open for hearing and determination.” This includes the incorrect finding by the first jury that Tuomey violated the Stark Law. Again, we are pleased with this news and we will keep you posted as we learn more.

Setback to Plaintiff’s Qui Tam Bar?

The original decision in Tuomey had encouraged plaintiff’s attorneys who take whistle-blower cases in health care matters and had alarmed health care systems across the country.  Although this does not eliminate the ability to use Stark Act violations as the basis for False Claims Act recoveries, it does indicate that the courts will require strict pleading, proof and procedural rules before it does allow this.

Sources Include:

Blesch, Gregg, “Appeals Court Overturns Order for S.C. Hospital to Pay $45 Million in Stark Case,” Modern Healthcare (Apr. 1, 2012). From:
http://www.modernhealthcare.com/article/20120401/NEWS/304019973/appeals-court-overturns-order-for-s-c-hospital-to-pay-45-million-in#

Cheung, Karen M., “Federal Appeals Court Overturns $45M Stark Ruling,” FierceHealthcare (Apr. 2, 2012). From:
http://www.fiercehealthcare.com/story/federal-appeals-court-overturns-45m-stark-ruling/2012-04-02

Cox, Jay, “Federal Case Update,” Tuomey Healthcare System Press Release (Mar. 31, 2012).

Cox, Jay, “Federal Case Update,” Tuomey Healthcare System Press Release (Mar. 31, 2012). From: http://www.tuomey.com/Articles/federal_case_update.aspx

Davis, Caralyn, “Stark Violations: Tuomey Healthcare in South Carolina Ordered to Pay $50 Million,” FierceHealthcare (June 9, 2012). From: http://www.fiercehealthfinance.com/story/stark-violations-tuomey-healthcare-s-c-ordered-pay-50-million/2010-06-09

HHS, “Medicare and Medicaid Programs: Physicians’ Referrals to Health Care Entities With Which They Have Financial Relationships,” 66 Fed. Reg. 856, 941 (Jan. 4, 2001). From:  http://www.gpo.gov/fdsys/pkg/FR-2001-01-04/pdf/01-4.pdf

U.S. ex rel. Drakeford v. Tuomey Health.Sys., Inc., 4th Cir., No. 10-1819 (Mar. 30, 2012). From: http://pacer.ca4.uscourts.gov/opinion.pdf/101819.P.pdf

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

Health Care Professionals and Providers Beware: The Health Care Fraud Prevention and Enforcement Action Team (HEAT) Is Catching Fire

8 Indest-2008-5By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

In May 2009, the Department of Health and Humans Services (HHS) and the Department of Justice (DOJ) created the Health Care Fraud Prevention and Enforcement Action Team (HEAT). HEAT’s mission is to focus its efforts on preventing and deterring fraud and to enforce current anti-fraud laws around the country. To date, almost 1,400 individuals have been charged in connection with schemes involving more than $4.8 billion in fraudulent billings in these HEAT takedown operations.

To learn more about HEAT, click here to visit the website.

The Success of the HEAT Team.

According to the website, between 2008 and 2011, HEAT actions led to a seventy-five percent (75%) increase in individuals charged with criminal health care fraud. So far there have been six nationwide HEAT sting operations.

In 2011, HEAT agents led the largest-ever federal health care fraud takedown involving $530 million in fraudulent billing. To read more on this sting, click here.

On May 14, 2013, the DOJ announced that more than 400 law enforcement officials with HEAT spread out between eight cities including Miami and Tampa Bay to arrest 89 people accused of false billing. A majority of these arrests were allegedly of health care professionals. Click here to read a blog with more information on this takedown.

HEAT Captures One of Medicare’s Most-Wanted Fugitives.

On June 1, 2013, a former Los Angeles physical therapy clinic owner, and one of Medicare’s most-wanted fugitives, was arrested by HEAT agents at the Los Angeles International Airport on his return flight. According to a Los Angeles Times article, the clinic owner was an acupuncturist who billed Medicare for $2.1 million in false claims and was paid about $1.2 million. To read more from the Los Angeles Times, click here.

Expanding the Medicare Fraud Strike Force Efforts.

HEAT is a multi-agency team of federal, state and local investigators who combat Medicare fraud through the use of Medicare data analysis techniques and an increased focus on community policing.

The Affordable Care Act has given HEAT additional tools to preserve Medicare by expanding the team’s authority to suspend Medicare payments and reimbursements when fraud is suspected.

To better combat fraud, the government has established HEAT in a number of cities, such as Los Angeles, Miami, Tampa Bay, Houston, Dallas, Chicago, Brooklyn, Baton Rouge and Detroit.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent health care providers in Medicare audits, ZPIC audits and RAC audits throughout Florida and across the U.S. They also represent physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Comments?

Have you heard of HEAT? Do you think the team’s efforts are curbing Medicare fraud around the country? Please leave any thoughtful comments below.

Sources:

Department of Justice. “Medicare Fraud Strike Force Charges 89 Individuals for Approximately $223 Million in False Billing.” Department of Justice. (May 14, 2013). From: http://www.justice.gov/opa/pr/2013/May/13-crm-553.html

Terhune, Chad. “One of Medicare’s Most-Wanted Fugitives is Arrested in L.A.” Los Angeles Times. (June 3, 2013). From: http://www.latimes.com/business/money/la-fi-mo-medicare-most-wanted-fugitive-arrest-20130603,0,7474342.story

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Preparing for a Florida Board of Medicine Informal Hearing

by George F. Indest III, J.D., M.P.A., LL.M.
Board Certified by The Florida Bar in Health Law

If you are scheduled to appear for an informal hearing before the Florida Board of Medicine, there are a number of facts that you will want to know in order to be properly prepared.  This article will cover many of them.

Limited Circumstances for Informal Administrative Hearing

First, you should understand that you will only be at an informal hearing in which you appear before the Board of Medicine itself for a very limited number of reasons.  These will include the following:

  • If you completed an election of rights (EOR) form and agreed that you did not intend to dispute any material facts alleged against you from the administrative complaint (AC) in the case.
  • If you entered into a settlement agreement (or “stipulation”) (similar to a plea bargain in a criminal case) in which you agreed to accept discipline against your license.
  • You failed to submit any election of rights (EOR) form and failed to file a petition for a formal hearing in a timely manner, and, therefore, you have waived your right to a formal hearing.

There are a few other circumstances in which there may be an informal hearing before the Board, such as motions to modify a final order, motion to lift a suspension of a license, appearance in accordance with an earlier order, petition for a declaratory statement, or other administrative matters.  This article only discusses those directly relating to disciplinary action as indicated above.

What an Informal Administrative Hearing Is Not

  1. An informal administrative hearing is notan opportunity for you to tell your side of the story.  You have agreed that there are no disputed material facts in the case or you would not be at an informal hearing.
  2. An informal administrative hearing is not an opportunity for you to prove that you are innocent of the charges.  You have agreed that there are no disputed material facts in the case or you would not be at an informal hearing.
  3. An informal administrative hearing is notan opportunity for you to introduce documents or evidence to show that someone else committed the offenses charged and you did not.  You have agreed that there are no disputed material facts in the case or you would not be at an informal hearing.
  4. An informal administrative hearing is not an opportunity for you to argue that you should not be in the board’s impaired practitioners program (either the Professionals Resource Network (PRN) or the intervention Project for Nurses (IPN)) because you have completed a different program or that you do not have a problem.  These are the only programs recognized and used and you have agreed that there are no disputed material facts in the case or you would not be at an informal hearing.

Formal Administrative Hearing vs. Informal Hearing

If you desire to contest the facts alleged against you then you must state this in writing.  If the material facts in a case are challenged by you, then the Board or the Department of Health (DOH) (note: all professional boards are under the Department of Health in Florida) must forward your case to the Division of Administrative Hearings (DOAH) where a neutral, objective administrative law judge (ALJ) will be appointed to hold a formal hearing in your case.  This is the only way that exists for you to prove that the facts alleged against you are incorrect or that you are not guilty of the charges made against you.  In fact, you do not even have to do anything in such a case.  The Department of Health has the burden of proof and it has to prove the charges against you and the material facts alleged against you by clear and convincing evidence.  Often, it is unable to do this at a formal administrative hearing.

However, because of the technicalities of evidentiary law and administrative law, we do not recommend that a nonlawyer attempt to represent himself or herself at such hearings.  You can make technical mistakes (such as answering requests for admissions incorrectly) that severely compromise any defense you may have.  We recommend that you always retain the services of an experienced health lawyer in any such matter.

What to Do If You Find That You Are at an Informal Hearing and That You Do Desire to Contest the Material Facts of the Case (And Your Guilt or Innocence)

If you have been scheduled for an informal administrative hearing and you decide that you do desire to challenge the material facts alleged against you in the administrative complaint (AC), file a written objection to proceeding at the informal hearing.  State that you have discovered that there are material facts that you do desire to challenge and that you desire that the proceedings be converted to a formal hearing.  File this with the Clerk of the administrative agency you are before (usually the department of health or the Agency for Health Care Administration (AHCA) and also send a copy to the opposing attorney and the executive director of the Board.  Do this as early as possible and keep proof that you have actually and filed the written request.

If you are already at the informal hearing when you discover this, object to the proceedings on the record and ask to have the informal hearing be converted to a formal hearing where you may contest the material facts.  State this as many times as reasonably possible.

Preparing for an Informal Hearing

Since you are not contesting the facts alleged against you, if you are going to an informal hearing be sure you do the following:

  1. Be sure you know where the hearing is going to be held.  Try to stay the night before in the same hotel as the hearing will be held.  You will usually have to make these reservations early in order to get a room.
  2. Attend a Board meeting that occurs before the one at which your case is scheduled.  This will give you a feeling for the procedures that will be followed, will help to make you less nervous when you appear, and you can obtain continuing education units for doing so (be sure to sign in and sign out).  Be sure to attend one of the days when the disciplinary hearings are held.
  3. Dress professionally for the appearance.  This may be the most important event in your professional career.  For men, this means a suit and tie or, at least, a dark coat, dark slacks and a necktie.  For women, a professional business suit or the equivalent is in order.  Do not dress as if you are going to the park, the beach or out on a date.  Do not wear sexually provocative or revealing clothing.
  4. Check the agenda that is published on line a day or two before the scheduled hearing to make sure that your case is still scheduled for the date and time on the hearing notice.  Informal hearings may be moved around on the schedule.  Make sure you are there at the earliest time on the hearing notice or agenda.
  5. Listen to questions asked of you by Board members and attempt to answer them directly and succinctly.  You will be placed under oath for the proceeding and there will be a court reporter present as well as audio recording devices to take everything down.
  6. Do not argue with the Board members or lose your temper.  This is not the time or place to let this happen.  If you have such tendencies, then you should have an attorney there with you who can intercept some of the questions and can make defensive arguments (to the extent that they may be permitted) for you.
  7. You may introduce documents and evidence in mitigation.  However, you have agreed that the material facts alleged are true, so you may not contest these.  In effect, you have plead guilty and you are just arguing about how much punishment (discipline) and what kind of punishment you should receive.
  8. If you do intend to introduce documents and evidence in mitigation, be sure you know what the mitigating factors are (these are published in a separate board rule in the Florida Administrative Code for each professional board).  These may include, for example, the fact that there was no patient harm, that there was no monetary loss, that restitution has been made, the length of time the professional has been practicing, the absence of any prior discipline, etc.  You should submit these far ahead of time with a notice of filing, so that they are sent out to the board members with the other materials in your file.  This is another reason to have experienced counsel represent you at the informal hearing.
  9. Be prepared to take responsibility for your actions.  If you are not prepared to take responsibility, then this means you must believe you are innocent and you should be at a formal hearing, not an informal one.
  10. Be prepared to explain what went wrong, why it went wrong, and what remedial measures you have taken to prevent a recurrence of this type of event in the future.  Show that you have learned from this experience and that you are not going to make the same mistake again.
  11. It is our advice to always retain the services of an experienced attorney to represent you at such hearings.  Often your professional liability insurance will cover this.  If you have professional liability insurance, be sure that it contains a rider or addendum that provides coverage for professional license defense matters and administrative hearings.  You need at least $25,000 to $50,000 in coverage for this type of defense.  If necessary, you should contact your insurer or insurance agent and have the limits increased for a small additional premium

Other Little Known Facts to Remember

Professional licensing matters are considered to be “penal” or “quasi-criminal” in nature.  Therefore, you have your Fifth Amendment rights in relation to being required to give evidence against yourself.  You cannot be compelled to do this in such matters.  However, since it is an administrative proceeding and not a criminal proceeding, there is no requirement that the licensee be advised of this by a DOH investigator or attorney.

If you enter into a settlement agreement and attend the informal hearing to approve it, nothing you say or testify to at this hearing can later be used against you.  This is because you are involved in an attempt to negotiate and settle (or compromise) the claims being made against you.  It is a general rule of law that nothing the parties say in such settlement proceedings can later be used as evidence if the settlement agreement is not approved.  The law tries to promote settlements among parties to any dispute in this way.

It is true that on occasion the Board will examine a case on an informal hearing and will decide to dismiss it.  This is rare, but it does happen.  Sometimes, it will be a tactical decision on the part of you and your attorney to elect to go to an informal hearing with the hope that the Board may examine the case and decide to dismiss it.  However, you cannot count on this happening.

Don’t Wait Too Late;  Consult with an Experienced Health Law Attorney Early

Do not wait until action has been taken against you to consult with an experienced attorney in these matters.  Few cases are won on appeal.  It is much easier to win your case when there is proper time to prepare and you have requested a formal hearing so that you may actually dispute the facts being alleged against you.

The lawyers of The Health Law Firm are experienced in both formal and informal administrative hearings and in representing physicians in investigations and at Board of Medicine hearings.  Call now or visit our website www.TheHealthLawFirm.com.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

The American Academy of Family Physicians Releases Third List for Choosing Wisely Campaign

IndestBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On September 24, 2013, the American Academy of Family Physicians (AAFP) released its third list of commonly prescribed tests and procedures that may not be necessary. This list is part of the American Board of Internal Medicine (ABIM) Foundation’s Choosing Wisely campaign.

The Choosing Wisely Campaign was initiated to give patients a catalog of procedures, tests and treatments that have been overused, misused or have been identified as ineffective. Since its launch in April 2012, more than fifty (50) medical specialty societies have created lists of procedures, tests and drug treatments that deserve to be questioned before a physician orders them or patients accept them.

The purpose is to help patients become more discriminating about what care they receive. Physicians and health care providers also need to use this information to review the latest research and use that information to help avoid any litigation.

I’ve previously written about the Choosing Wisely campaign. Click here for part one and here for part two.

AAFP’s Updated List of Commonly Prescribed Tests and Procedures That May Not be Necessary.

1. Do not prescribe antibiotics for otitis media in children aged 2-12 years with non-severe symptoms where the observation option is reasonable.

2. Do not perform voiding cystourethrogram routinely in first febrile urinary tract infection in children aged 2-24 months.

3. Do not routinely screen for prostate cancer using a prostate-specific antigen (PSA) test or digital rectal exam. Evidence suggests that PSA-based screening leads to an overdiagnosis of prostate tumors.

4. Do not screen adolescents for scoliosis. Potential harms include unnecessary follow-up visits resulting from false-positive test results.

5. Do not require a pelvic exam or other physical exam to prescribe oral contraceptive medications. Hormonal contraceptives are safe, effective, and well tolerated by most women.

Click here to read the AAFP’s previous recommendations.

Health Care Providers and Professionals’ Responsibility to Patients.

A doctor should have the knowledge, skill, training, and confidence to know when such tests and procedures are not warranted. Also, a health care professional or provider should not be swayed by increasing his/her personal bottom line. Specifically, physicians that work in a fee-for-service setting that rewards doctors for performing more procedures are at risk for ordering unnecessary tests or procedures. If a physician persists in ordering these tests solely for the means of increasing profits, he or she should be penalized. If not, the physician should be able to justify them.

Laws Protect Patients from Unnecessary Testing.

This situation may have the side effect of promoting additional litigation against doctors, healthcare clinics and hospitals that provide the unnecessary tests and procedures. Many states have laws that prohibit unnecessary tests and procedures and sanction those who provide them. For instance, Section 766.111, Florida Statutes, provides a private cause of action by a patient against a health provider who orders or furnishes such “unnecessary” diagnostic tests, but unlike other tort and medical malpractice statutes, it allows the prevailing party in such a case to recover attorney’s fees and costs. This law may by itself promote litigation in the face of the lists of tests produced by the specialty groups in the Choosing Wisely campaign.

Look for More Whistleblower/Qui Tam Cases.

As this list continues to grow, I believe that we will see more qui tam/whistleblower and false claims cases.

Qui tam cases have been brought under the federal False Claims Act for the recovery of Medicare payments from hospitals, physicians, nursing homes, diagnostic testing facilities, clinical laboratories, radiology facilities and many other types of healthcare providers. These cases allege that a false claim was submitted to the government. If the test or procedure was unnecessary, then it seems almost axiomatic that a claim for it is false. The plaintiff bringing such cases receives a percentage of the recovery, which often amounts to millions of dollars in successful cases.

Most states now have similar false claims act or qui tam laws providing similar causes of action and recoveries to individual plaintiffs in the case of state Medicaid payments as well.

Because medical necessity is a requirement for practically every Medicare and Medicaid service, as well as most services paid by private health insurers, the lists provided by the specialty may very well be exhibit one in future lawsuits.

We’ve recently written about a couple of whistleblower/qui tam cases stemming from unnecessary procedures. To read a blog on a group of Florida radiation oncology service providers accused of performing unnecessary and improperly supervised procedures, click here. To read a blog on Winter Park Urology’s settlement over allegations stemming from radiation therapy used to treat cancer patients, click here.

Contact Experienced Health Law Attorneys.

The Health Law Firm routinely represents pharmacists, pharmacies, physicians, nurses and other health providers in investigations, regulatory matters, licensing issues, litigation, inspections and audits involving the Drug Enforcement Administration (DEA), Federal Bureau of Investigation (FBI), Department of Health (DOH) and other law enforcement agencies. Its attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.
To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Comments?

As a health care professional or provider what do you think of the Choosing Wisely campaign? Please leave any thoughtful comments below.

Sources:

Hand, Larry. “AAFP Releases Third Choosing Wisely List.” Medscape. (September 25, 2013). From: http://www.medscape.com/viewarticle/811638

Carman, Diane. “Useless, Costly Medical Procedures Targeted by Choosing Wisely Campaign.” Health Policy Solutions. (October 15, 2013). From: http://www.healthpolicysolutions.org/2013/10/15/useless-costly-medical-procedures-targeted-by-choosing-wisely-campaign/

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2012 The Health Law Firm. All rights reserved.

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