AHLA's Speaking of Health Law
AHLA's Speaking of Health Law
Trends and Developments Related to Health Care Fraud Settlements
Joe Wolfe, Attorney, Hall Render Killian Heath & Lyman PC, speaks with Marissel Descalzo, Partner, Tache Bronis and Descalzo PA, about the current landscape of health care fraud settlements and enforcement activity. They discuss what triggers a false claim and accompanying investigation, what drives whistleblowers, patterns with respect to false claims cases, examples of recent enforcement actions, areas the Department of Justice is targeting, future enforcement trends, and OIG’s November 2023 compliance program guidance document. They also discuss the second edition of AHLA’s publication, Health Care Fraud Settlement Index. From AHLA’s Fraud and Abuse Practice Group.
Watch the conversation here.
To learn more about AHLA and the educational resources available to the health law community, visit americanhealthlaw.org.
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Speaker 2:This episode of A HLA speaking of Health law is brought to you by A HLA members and donors like you. For more information, visit American Health law.org.
Speaker 3:Uh, welcome everyone to today's A HLA podcast where we will be talking about trends related to healthcare fraud settlements. There's a , a lot we intend to cover in today's podcast related to trends. Um, and, and also in conjunction with the ALA's just released Healthcare Fraud Settlement Index. I have a copy of it right here, the second edition , uh, which breaks down different settlements in the market. Um, and it, it does it in a , in a nice way. And I would encourage anyone listening into , uh, or, or that are watching the video podcast to look into this, it, it breaks out different settlements in the market related to the types of fraud allegations. So False Claims Act , stark Law , uh, and a kickback statute allegations. And then it also breaks it out by , um, state where the , uh, where the action occurred. And then , uh, as an apart related to the facilities , um, where the fraud settle is related to. But I just wanted to, to touch on that, that it does tie into today's session. We're not gonna go into the weeds on the book itself, but it , uh, does highlight the fact that we are able to publish a fraud settlement index. It , it , it shows that , that there is significant movement and activity related to , uh, fraud settlements , um, in the market. Lots to cover today. My guest , uh, today is Mariel Scalzo from Attack Bros . And Scalzo . Uh , and she and I are gonna talk through Fraud Settlements. A little background. Uh, she and I are both , uh, licensed in the state of Florida. Um, we're presenting at a conference , uh, earlier this year, and I , when I saw her presenting, I thought, man, we should have her as a guest to talk about , uh, fraud settlements. Obviously, there always is lots going on in the state of Florida , um, and, and I'm sure she'll be able to , uh, provide us with some, some context on that market. And then more broadly, as we think about , um, uh, fraud settlements , uh, today's podcast, video podcast is brought to you by the American Health Law Association's Fraud and Abuse Practice Group. Uh, I currently chair the Practice Group, and our mission is to help our members stay informed about healthcare fraud and abuse and compliance issues. Uh, we're getting to, we're just starting a new program year right now, and our vice chairs are eager , um, and are doing a great job of developing webinars, publications, and other content , uh, to educate our members. But before we get into the, the back and forth , uh, Marisol , can you please , uh, introduce yourself?
Speaker 4:Sure. And, and first of all, thank you, Joe and a HLA for having me on this podcast. I'm excited to, to have this conversation with you. Uh, today. Um, I am, like you mentioned, I'm from Florida. Uh , my office is in Miami. Um, but I have an actual na , I actually have a national practice , um, where I focus on white collar criminal defense and , uh, the defense of False Claims Act cases. But I specialize in healthcare fraud , uh, prosecutions and healthcare fraud defense in the false claims , uh, arena. And , uh, uh, so I have cases , uh, lots of cases , uh, all over the place. Uh, but my base is in Miami.
Speaker 3:Great. Um, and as I , I mentioned, I'm, I'm Joe Wolf. I chair the Fraud Abuse Practice Group , uh, for a HLA. I'm a shareholder , uh, with Hall Render and the practice group leader for Hall , hall Renders Health Regulatory Practice Group. And like Mari will have a very national practice focused on , um, fraud and abuse , uh, stark law compliance , uh, provider compensation models , uh, value-based care , um, all related to healthcare . Um, so we're gonna get into a little bit of the, the trends related to settlements in the fraud , in the fraud and abuse and , and fraud settlement space. Before that, I just wanted to give just a brief background on, on what we may mean by whole , our healthcare fraud settlements. Um, we're typically talking about claims under the False Claims Act. Uh, the Stark Law, the Anti-Kickback Statute , uh, and their state law equivalence , um, is, I'm sure many of you listening in because you're listening to this kind of a podcast, probably have some background on those laws. But the Anti-Kickback statute , um, is a , is a, a fraud statute that focuses on , uh, healthcare providers potentially exchanging remuneration in exchange for , uh, healthcare items or services that are payable under federal healthcare programs. That is an intent based statute. There's a , there were requirements under it relating to whether there the conduct was knowing and willful , um, and , and so on. And so, the relevant inquiry in , in , let's say, an anti-kickback statute claim focuses on the , the subjective intent of the parties. Um, so I mean, that's anti-Kickback Stark as a much more technical law. Um, they play in under the False Claims Act. We may get into this , um, and , and whether or not a, a false claim was triggered or predicated by Anti-Kickback or , um, uh, a Stark Law violation. Um, and of course, there's the bread and butter, which is situations related to over billing upcoding , um, and we may get into that as well. Um , but again, those, the anti-Kickback statute in Stark Law , uh, can serve as the basis for liability under the False Claims Act. Um, and so, you know, that's a, a bit of high level , uh, background on, on fraud claims, fraud and abuse issues, and what may drive a fraud settlement. Um, and I'm gonna get in some back and forth with , uh, Mariel , and , and I'd start by, you know, Mariel , from your vantage point, what often triggers a , a false claim in , in your experience?
Speaker 4:Well, there's lots of things that can trigger a false claim , uh, because, so essentially, a false claim is in , in simple terms, it's when any person submits a claim that they know is false to Medicare for payment. Um, and some typical examples are a, maybe a physician submits a claim for services that he knows or she knows he did not provide. But then there's other , uh, things that can give rise to a false claims , uh, violation. You mentioned an a KS violation. So if a claim is premised on a kickback, that can also be , uh, rendered a false claim because , uh, you have to sign or certify that you are , uh, complying with all state and federal laws when you submit any claim to Medicare. Uh, if you're violating the a KS , you're not complying with the law. Um , and so that is , uh, a trigger as well. So there's lots of things, and it's a highly regulated area. And , and , and , and you really have to, you know, all practitioners need , need to be careful. Um, Joe , can you tell us what is usually the genesis of a false claim investigation?
Speaker 3:Yeah, thanks. Uh , Mariel , you know, the , every investigation has facts and circumstances that are driving , uh, the, the a allegations. Um, and that's something that we always need to think about. You know, if, if you're, if you're working in the compliance department and you're thinking, you know, you're working on a physician contract , uh, for example , um, you know, understanding the facts and circumstances and how an arrangement may be framed and how defensibility would, could ultimately be tested, and what kind of position you would take to defend that arrangement, I think is a thoughtful and helpful process for anyone from the get go . Um, you know, an arrangement that triggers an an investigation , uh, down the road is often brought by , uh, a whistleblower. Um, you know, it's someone who is close to the arrangement and identifies , uh, issues with it. Maybe they're not heard out once those issues , um, are brought to light , um, and then eventually become a whistleblower down the road. And so , uh, having a, a thoughtful compliance program that addresses concerns, that focuses on defensibility, that develops a record that supports arrangements that are going to be more defensible down the road, or a, a way to reduce the risk of a false claims investigation , uh, down the road. Data outliers can drive this, you know, the government becoming aware of, of outliers , um, from a coding standpoint, from a billing standpoint. Um, that could be a way that , um, an action may be brought outside of a whistleblower , uh, context. Uh, you can even have situations where , uh, criminal investigations can be launched related to a false Claims Act investigation as well . Um , you know, if your organization , uh, is going to be brought into a situation where there may be a false claims investigation and challenge , uh, you may receive a civil investigative demand asking for certain types of document or information from the government , um, as they start to unpack , um, and understand the facts and circumstances. Um, and that process can be very drawn out. But the genesis is, is usually facts and circumstances , uh, sometimes confusion or individuals who feel like their concerns are not addressed. Uh, that's the practical driver of many of these situations. Um, and, and that's the unique opportunity at the beginning to try to address and reduce the, the risk of an eventual false claims Act investigation. Uh, you know, Mariel thinking about , uh, whistleblowers and , and , you know, we do know that many of these investigations begin with whistleblowers. Uh, why do you think they , um, you know, bring these actions? What, what drives them to reporting and bringing forth , uh, allegations , uh, in this space?
Speaker 4:I think there's , uh, two types of whistleblowers. There's the, the, the money driven ones <laugh> , uh, 'cause there's a, it's a huge payday , uh, uh, for a whistleblower to bring one of these actions. I mean, it's, it's, it's sometimes it's sufficient money that they can probably retire more money that they've seen, you know, in all their lives. And so , uh, I think money is a big motivator. And it's no secret that that is why, you know, the , the, the government dangles that carrot of, you're gonna get some , some portion of this to bring more people to come forward. Uh, 'cause clearly the government can't do all the enforcement on their own. I think there's also another subset of whistleblowers that are, do-gooders, you know, physicians, compliance personnel who, you know, feel , uh, that healthcare organizations need to be doing the right thing, that practitioners need to be doing the right thing. And they feel either morally motivated or ethically , uh, motivated to tell , um, you know, to to , to right the wrong. Um, and those are more dangerous, I feel, for companies and , and healthcare providers because they really , uh, you know, are in there investigating. And , um, um, they, they, they really , uh, you know, have a vested interest when they're not motivated only by money. Um, Joe, you wanna tell us, you know, are you seeing a pattern with respect to false claims cases in your area?
Speaker 3:Yes. I , you know, we, we see some of the consistent cases that we've seen for, you know , the past 15 years in particular focused on , um, physician compensation, provider compensation in my space, most of my practice is focused on , uh, provider compensation , uh, issues , uh, stark and kickback compliance defensibility in that space. And so we're seeing a continuation of some of the , uh, trends that we saw before, which is allegations on the big three that arrangements are exceeding fair market value , uh, that they're not commercially reasonable , um, and perhaps that they've taken into account referrals. Um, the government has provided a bit more clarity around the legal standards , um, related to those issues. But we're still seeing , um, ongoing , uh, allegations , uh, related to , um, those arrangements in some recent cases. Um , we've seen a bit more granularity around issues of, of fair market value , um, and process around fair market value. And so I do think that that's an area that healthcare organizations should be focused on, you know, how they're going about establishing defensibility around those big three , uh, because they may be subject to more , um, specific and, and granular challenges. Um, on that , uh, the trends beyond that, I think, you know, we've seen more and more discussion of, of Medicare Advantage , um, enforcement. Um, we're seeing , uh, more and more discussion about, you know, the, the future state of physician arrangements. And when we may see , um, in investigations related to the actions taken during covid . Um, I, I do anticipate we'll see in the future , uh, trends towards , uh, challenges around value-based care as well. But in , in many instances in my space, we're , when we are seeing , uh, civil investigative demands, they're focused on the physician compensation models , um, and challenges , uh, to those models as well. And so , I mean, the, and and stepping through that, you know, the , the pattern , um, is really continuing to fall back to that big three though , uh, you know, Marisol in your space, do you have any examples that you wanted to provide of recent enforcement actions , uh, that you wanted to touch on?
Speaker 4:Sure. And you, you mentioned Medicare Advantage. And, and , and I'll say that is a big target area , uh, for the Department of Justice. Uh, when I am , you know, going to , uh, continuing education courses, and when I'm speaking to my friends at DOJ , they're constantly talking about Medicare Advantage. That's what they're focused on. And so recently , um, you know, with that theme, Cigna had to settle a case for $172 million. Um, and it's , uh, it , it was based on their failure to submit , um, and or failure to withdraw inaccurate and untruthful diagnosis codes for their Medicare Advantage plan enrollees. Um, and basically , uh, you know, the government , uh, alleged that, that Cigna was engaged in chart review, and that they were paying vendors to go and assess patients , uh, at home. And that they were using these assessments , uh, to bill , uh, falsely , uh, without doing any due diligence to make sure that they were accurate. And, and then falling from that , um, some individuals were charged as well. Um, but, but, but Cigna really got dinged for that. And , and there's gonna be more of that because it's just , uh, it's a money rich area , uh, where the government can recover lots of funds. Um, and , and Joe, how , how about you? What recent enforcement actions , um, have you seen on your end?
Speaker 3:Yeah, I would agree. I , I do think, you know, to your point that, you know, managed care is, is in the cross. Heres a bit as we think about Medicare Advantage and, and managed care generally, and, and I think you mentioned, you know, that a very, very important case. And, you know, seeing allegations around , uh, chart reviews , uh, for Medicare Advent Advantage beneficiaries , uh, diagnosis codes, and whether those codes are submitted , um, you know, those types of, of allegations, I think we're gonna continue, you know, to see more of , um, in , in , in looking at , uh, the recent, you know, case law and, and you know, what, what is, what are things gonna look like? I think we're gonna continue to see allegations related to , um, the Covid period and steps that were taken during that period. Um, we continue to see the data sort of showing that these false claims act ca uh , claims are on the uptick. And so I do think getting your arms around what actions were taken during the period during Covid , whether you were relying on some type of waiver, that that's a good use of, of time and effort now to make sure you're in a position to, to get ahead of some of those, those issues. So , um, you know, I, I think we're gonna continue to see an uptick in that area. So , um, Mariel , as you think about 2024, what areas do you see the DOJ targeting? Um, you know, are there any areas in particular?
Speaker 4:Yes. I mean, I , I already mentioned Medicare Advantage, but , uh, and you touched on, on COVID-19 , uh, anything pandemic related is just the government wants is finally coming after it. I have , uh, you know, I have one COVID testing site, lab case indicted. I have two under investigation. There's more I'm sure that are gonna , that are gonna start , um, you know , uh, getting indicted. Uh, the government's still going after the labs and the genetic testing. Um, there's also , uh, you know, anything with , uh, prescription drugs, they're still interested in that. Um, and also antitrust violations in the healthcare , uh, sphere. We heard about this, you know, a couple years ago, the government , uh, started investigating, you know, allegations that , uh, you know, doctors couldn't jump from one place to another. Nurses couldn't, you know, jump from one place, from one job to another. There was agreements not to allow this. Um, the government decided, you know, that decided that's an antitrust violation, decided that they were, that this was gonna be an area and a focus of prosecution. Um, the government, frankly, has lost a lot of those cases. Um, but they, they continue to, to, for , you know, to, to be interested in it. And it continues to be a focus area. So we're gonna see some more of those cases coming, I think in 2024 , um, keeping that antitrust division busy. Uh, and , uh, and, and so that's what I'm seeing from, from my end. Now, Joe, I , I just talked about 2024. Do you have any insight on what future trends in enforcement could be, especially now that, you know, know the Chevron doctrine was overturned, there's the ER case. Uh, any other things that from your perspective are , are gonna be now , uh, you know, places where, where the government will target?
Speaker 3:Yeah, I think , um, we're gonna continue to see the trend upward , um, in the, the data related to the number of claims that are filed. I mean, if you follow that trend line, you know , if I go back to 2022 and the reported data, you , you talked about, we , we saw like 2.2 billion in, in FCA settlements and judgements , um, over 1.7 billion of that was , uh, related to healthcare industry. We saw , uh, almost a $500 million paid to Relators. And, and some of the data I saw, it's 658 key TAM suits filed an interesting development. 305 of those , um, were non-key TAM suits that were filed as well. So that's an interesting area. You know, maybe we could see more and more development and less reliance on whistleblowers as the cases grow , um, over time. But then if you look at the 2023 data, we saw a jump from about 2.2 billion to 2.6 billion , uh, bigger , um, uh, chunk of that was in healthcare. Uh , key TAM suits over 700. Um , so that shows you these continue to grow and snowball, and then 500 non KET TAM suits filed . So this is a trend I think we need to keep our eyes on just where the enforcement is coming from. But I think we're gonna see those numbers , um, continue , uh, to rise. Um, I think as from a trend standpoint, we're going to continue to see consistent numbers around self disclosures, because as we mentioned, a lot has happened , um, during the Covid pandemic. Um, and we, as there's more attention brought to some of these issues that are unfolding, and we saw over the last , uh, year, I , it's a trend I didn't mention, but more focus on , uh, advanced practice providers and support provided to physicians , um, through the use of those apps. Um, and some recent , um, uh, settlements there. I think we're gonna see proactive compliance efforts from healthcare organizations , uh, to take their , uh, issues through the self-disclosure process. 'cause it's definitely , um, a , a luxury to resolve issues through self-disclosure, rather than run the risk of, of very large damage figures in an eventual , um, enforcement action . So I think we're gonna see from a trend standpoint, more and more , uh, self disclosures , uh, going, going forward. Uh, as I mentioned before, managed care, I think continuing to be , um, in, in the, in the crosshairs as well. Um, and then with regard to the, you know, kind of the case law development related to Chevron , um, and the overturning of Chevron, you know, I, I think it's a bit of wait and see , um, as we look at courts and, and how they're going to interpret agency guidance going forward. You know, what is that going to mean for providers? I've, I've heard some , uh, in some , uh, webinars talking about the Chevron change that , uh, the healthcare organizations should even fall back and understand all of the positions that they've , they've taken and whether or not they should be, that they may have more leniency in certain areas than they did before. And what that means. Um, you know, on the flip side, I think there could be an opportunity for whistleblowers to bring , um, allegations similarly where , uh, perhaps the actions taken , um, were not in line with the statute, but they were relying more on agency guidance. So it's, it's a , I think it's gonna be a bit of, of wait and see as we think about the impact of, of post chevron. Um, I just think, you know, we, we all know that the changes here , um, will be, they , they will impact healthcare. It's a significant ruling, and it , it could impact and likely will impact the court's method of analysis for determining, determining lawful agency action. Um, and I think the decision was , uh, much broader than we anticipated, and its full impact against still remains unknown, so we'll , we'll have to see how it ultimately, ultimately plays out. Um , Mariel, from your vantage point, anything new on the horizon that you wanted to tell listeners about?
Speaker 4:Well, there's a , there's a couple things. There's, there's a new compliance program criteria , uh, which, which companies should know about . Um, and it's, and it's, you know, it's refined a bit. Um, but I think that the, the real thing that's on this , on the horizon is the government's new early disclosure program , um, in the healthcare space. And there is really a push to have companies come in and, and, you know, tell on themselves to kind of self-disclose and tell the government what they did wrong. And , uh, you know, put it out all out on the table and there's a reward for it. And the reward is you're gonna get less of a fine. Um, and, and the fine can be up to, you know, the, the, the , uh, discount can be up to 50% , uh, is what we're hearing , uh, depending on how much they , the government believes the company cooperated. So I think that that's something that is gonna continue to evolve. Um, it's, it's, Chevron was that settlement was the first one. I mean, I'm sorry, not Chevron. Cigna was the first , uh, you know , uh, settlement of that type. I think that there's gonna be more , uh, settlements of that kind in, in the future , uh, and more people are gonna be coming forward. And I know that there are some that are still under wraps , uh, that the government's not talking about. Uh, but, but big or small, the government wants you to come in and self-disclose, and they'll reward you for that. Um, at least reward the company. Um, and I think also, you know, parallel investigations continue to be a thing. And what I mean by that is that there's a civil investigation, there's a criminal investigation. They can both be going on at the same time. So , uh, you know, always be careful 'cause you don't know if it's gonna go criminal. And , uh, uh, you gave up too many , too much information during the civil process. Um, Joe, I mentioned the new compliance program. Is there anything that stands out to you about that new compliance program that you wanna tell, you know, that you tell your clients about?
Speaker 3:Yeah, and , and I, I would encourage anyone listening in to, if , if you haven't explored it, to take a look at the new general compliance program guidance that was issued by the OIG back in November of , of 2023. Um, it's a significant document, and I do think it's going to drive compliance and already is div driving compliance activities , uh, across healthcare. Um, if you're not familiar with it, it applies to all individuals and entities that are involved in the healthcare industry. And the guidance document talks about key aspects of general compliance, risk compliance infrastructure, and it , it, it addresses key federal authorities , um, for anyone engaged in healthcare business. It reiterates and, and expands upon the seven elements of a compliance program it has in their adaptations for small and large ENT entities and, and crew , and also discusses compliance considerations and , and OIG process and has resources in it. And it, much of what is in it is not new to healthcare that , to the industry, to all of us have who've been involved, but it reinforce reinforces best practices and recommendations from previous OIG guidance. And so it really becomes, it, it is a, that's why I said it's a significant document. It sort of has everything in there. And so if you're developing a program, a compliance program from scratch, or you're trying, you're taking, you're looking at it with fresh eyes, it's a , it's a significant document. And one I would , uh, look at and it gets into the weeds about, you know, the compliance officer, the responsibilities , uh, structure and operations and limitations. It talks about the compliance committee, the structure and operations of the compliance committee, and how to set the tone from the top. It gets into that discussion about risk assessments. There's discussion about quality and patient quality and patient safety considerations. And one thing that really jumped out is that the government talked in, in some length about , uh, the fact that compliance programs may differ based on the size of an entity, and that a compliance program for a small entity should be structured so that the entity can gain the benefits and protection of a compliance program within the constraints in which it operates. So there's an acknowledgement that smaller entities may not have the top of the shelf compliance program with all the bells and whistles that , um, another organization , uh, has. But it , it talks about , uh, but, but then it also says compliance leadership for large entities , um, should be aligned with the size and complexity of the organization. Um, and you should be reviewing the scope and adequacy of the, of your compliance program for those reasons. So if you have a, a significant organization with significant operations , uh, it is important to think about, you know, the size and capabilities of your compliance committee. If you're lean there , uh, that may not look good under the, the new, the , the November, 2023 guidance. Um, just one other thought on that compliance guidance is it discussed the increasing number of new entrants into the market, including technology companies and new investors and organizations that provide non-traditional services and healthcare settings. And, and , and said, you know, talked about how they may be unfamiliar with the unique regulations and business constraints that are applicable to the healthcare industry, and that they should be taking steps to ensure that they have the understanding of the federal fraud and abuse laws . You can't put your head in the sand here. If you're a new entrant, the government is saying, you, you have to be on top of this too. And certainly if you're accepting federal healthcare program reimbursement, you're certifying compliance with these laws. And so you need to get your arms around that. And so, you know, they're speaking to , uh, a, a and I, I agree, there's a whole new set of innovative players coming into this market, but this guidance is saying they need to be aware of these laws and developing compliance programs as well. So , uh, that, that, I can't say enough about that 2023 guidance. Um, and so , uh, you know, from your standpoint, you know, Maris , I just want to give you a chance to give any final remarks to our audience before we wrap up today. I've really enjoyed the conversation and the perspectives you brought , uh, to today's podcast.
Speaker 4:Thanks, Joe. I, I have two . I mean, I think my final remarks are just, just to touch on the, the, the new compliance program. Um, you know, I think it, it's , it's a warning sign to all these private equity companies coming into the market. Um, you know, they don't have the excuse anymore that they're far removed , uh, you know, from healthcare, and they don't understand the regulations. I mean, I think that this new program and this new guidance is like, no , you need to know, you need to make yourself , uh, you know, familiar. We're not giving you a pass anymore. Um, and , uh, you know, we already, we were already seeing some, you know, private equity enforcement actions, and I think that there's gonna be more , uh, just naturally because private equity really is coming into the space. Um, and so, you know, I wanna say that, and the only other thing I'll say is, you know, the disclosure program , uh, is not all it's cracked up to be. And I , uh, I, I just caution , uh, everyone , uh, companies, individuals , uh, you know, before you, you, you go in and you decide to cooperate with the government and disclose that you , you're giving up a lot, you're giving up a lot of rights. They're gonna expect you, they want, you know, they reward information. So if you give up your, you know, if you waive your attorney-client privilege, even if you don't have to, but they want you to, and they want you, you know, they want you to give up text messages and emails, and it really can open up a can of worm. So, but really, if you're gonna go down that route, really analyze all the pros and cons , uh, because it can be very dangerous. So thank you again, Joe, for having me.
Speaker 3:And Mariel, I'll just , uh, echo that. I mean, I think if you're going to go down the route of, of self-disclosure and using a self, going down the self-disclosure protocol route, you know, to Mariel's point you , it's really important that you do that in a thoughtful way. And I would say even , um, making sure you're counseled by someone with experience in that area, because it's, it's really important that , um, that you do that rigorous analysis that you outline and, you know, you, you're, you're able to describe how you remedied the situation and that it's appropriate going forward and what have you. And that , uh, you do that in a way that , uh, gives , uh, the government confidence that the issues have been dealt with and resolved because that's, that, that makes it less likely. You're gonna , you're gonna invite more questions , um, when you go about that, that self-disclosure. So I really appreciate , um, those comments. Well, thanks Maris Health for, for , uh, participating in this discussion on Fraud Settlements. Um, again, check out the, so the A HLA , uh, healthcare Fraud Settlement Index, the second edition. Um, it's, it's a great resource. Um, thanks to all of you for tuning in and , um, watch for upcoming , uh, content from the American Health Law Association , um, from the Fraud and Abuse Practice Group in the form of podcasts and webinars and, and written materials as well. I encourage you to , uh, consider attending the upcoming American Health Law Association Fraud and Compliance Forum , uh, that's in , uh, Octo from October 28th through 30th. Um, it's in Baltimore, like it is , um, uh, each year it's a great conference because , um, we do get a number of, of government participants 'cause we're, we're there in , in Baltimore, and , and you can hear their insights directly from them. Um, it , it's, it's a premier event from, from my perspective. Um, and I do encourage anyone listening in or watching to , uh, reach out if you're , uh, you'd like to volunteer to be on a future podcast or just get involved with the , um, fraud and abuse practice group. Uh, we would love to have more and more voices , um, and , and more and more , uh, in involved in trying to , uh, unpack some of the trends we're seeing in the industry and bring relevant content to our members and our listeners. So , uh, thanks again, Mariel . Thanks to everyone for tuning in , uh, and have a great day.
Speaker 4:Thank you.
Speaker 2:Thank you for listening. If you enjoy this episode, be sure to subscribe to a HLA speaking of health law wherever you get your podcasts. To learn more about a HLA and the educational resources available to the health law community, visit American Health law.org.