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DOJ Puts Academic Medical Centers in Spotlight

Client Alert | less than 1 min read | 11.29.12

On November 27, DOJ announced that Baylor University Medical Center has agreed to pay nearly $1 million to settle whistleblower claims brought under the False Claims Act, alleging that Baylor double-billed Medicare for certain procedures and billed for more expensive services when different, less expensive services should have been billed. The settlement, which DOJ hailed as an example of increased cooperation between DOJ and HHS under the Health Care Fraud Prevention and Enforcement Action Team (HEAT) initiative, follows a string of recent cases in which DOJ has targeted higher ed institutions under the FCA.


Insights

Client Alert | 4 min read | 11.09.26

CMS Finalizes Its 2026 Organ Procurement Organization Rule

On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions: ...