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Michigan Health Care Legal Blog

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Stark Law and Anti-Kickback Statute Compliance

Williamson Health Law has been recognized as one of the 2025 “Best Law Firms” by U.S. News & World Report and Best Lawyers®.

November 7, 2024

Williamson Health Law is ranked Metropolitan Tier I-Detroit in Health Care Law. This is the tenth consecutive year Williamson Health Law has been ranked by Best Lawyers®.

Best Law Firms rankings are based on a rigorous evaluation process that includes the collection of client and professional reference evaluations, peer review from leading attorneys, industry leader interviews and review of additional firmographic highlights provided by law firms as part of the formal research submission process.  Firms included in the 2025 “Best Law Firms” list are recognized for professional excellence with persistently impressive ratings from clients and peers. Receiving a tier designation reflects the high level of respect a firm has earned among other leading lawyers and clients in the same communities and the same practice areas for their abilities, their professionalism and their integrity.

Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, is also listed in The Best Lawyers in America® 2025, additionally named the 2025 “Lawyer of the Year” recipient by The Best Lawyers in America© for Health Care Law in Detroit. Ms. Williamson has been featured in the Best Lawyers listings since 2013, including recognition in 2022 as The Best Lawyers in America © Lawyer of the Year in Health Care Law in Detroit.

Deborah J. Williamson included in DBusiness magazine’s 2025 list of Top Lawyers

November 5, 2024

We are proud to announce that Deborah J. Williamson, Founder and Managing Attorney of Williamson Health Law, was selected by a vote of her peers to be included in DBusiness magazine’s 2025 list of Top Lawyers.

This esteemed list is published in the November/December 2024 issue of DBusiness magazine and online at www.dbusiness.com.

A lawyer’s selection as a Top Lawyer is based on an extensive peer-review survey of thousands of lawyers in the metro Detroit area (Wayne, Oakland, Macomb, Washtenaw, and Livingston counties).

Williamson Health Law Attorney Presides Over the 2024 Annual Meeting in her Role as Health Care Law Section Council Chair

September 19, 2024

We are thrilled to announce that Deborah J. Williamson, Founder and Managing Attorney of Williamson Health Law, presided over the Business Meeting portion of the September 19, 2024, Annual Meeting of the Health Care Law Section of the State Bar of Michigan in her role as the 2023-2024 Health Care Law Section Council Chair.  Congratulations to Deborah for leading this important gathering of healthcare lawyers in the final duty of her term as Chair.  Deborah will now serve another year on the Health Care Law Section’s Council as its Immediate Past Chair.

Congratulations Deborah! 

Williamson Health Law Attorney Named 2025 “Lawyer of the Year” Recipient by The Best Lawyers in America© for Health Care Law in Detroit

August 15, 2024

Deborah J. Williamson, founder and managing attorney of Williamson Health Law, has been selected for The Best Lawyers in America© 2025 for her work in health care law.

Williamson Health Law is also pleased to announce that The Best Lawyers in America© has additionally recognized Ms. Williamson as one of the 2025 “Lawyer of the Year” award recipients. She received this accolade for her work in Health Care Law in Detroit. Only a single lawyer in each practice area and community is honored with a “Lawyer of the Year” award.  Honorees receive Lawyer of the Year based on extremely high overall feedback for their professional excellence by their peers in the legal industry. 

Selection for The Best Lawyers in America© award denotes legal excellen

Attorney Deborah J. Williamson Named To 2024 Michigan Super Lawyers © List

WHL / August 12, 2024

Williamson Health Law founder and managing attorney Deborah J. Williamson has been named to the 2024 Michigan Super Lawyers © list for her work in health care law.

Super Lawyers is a rating service of outstanding lawyers from more than 70 practice areas who have attained a high degree of peer recognition and professional achievement. The selection process includes independent research, peer nominations and peer evaluations.  Only 5% of lawyers in Michigan have been recognized by Super Lawyers in this annual publication.

Williamson Health Law was founded in 2014 by Deborah J. Williamson, an attorney with over 25 years of experience with the legal and compliance issues affecting health care providers, payers and businesses. Williamson Health Law legal services include handling health care corporate and transactional matters, drafting and negotiating health care contracts, counseling on Stark Law and Anti-Kickback Statute compliance, performing regulatory analysis, advising on HIPAA breaches and compliance, appealing payer audits and overpayment demands, handling provider and payer disputes, defending professional license complaints, drafting and counseling on the implementation of compliance plans, and other legal services required by the health care industry.

 

Deborah J. Williamson included in DBusiness magazine’s 2024 list of Top Lawyers

November 13, 2023

We are proud to announce that Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, was selected by a vote of her peers to be included in DBusiness magazine’s 2024 list of Top Lawyers.

This esteemed list is published in the November/December 2023 issue of DBusiness magazine and online at www.dbusiness.com.

A lawyer’s inclusion as a 2024 Top Lawyer is based on the peer ratings of fellow attorneys.

Williamson Health Law ranked one of 2024 “Best Law Firms” in Health Care Law by U.S. News & World Report and Best Lawyers®

November 2, 2023

Williamson Health Law has been recognized as one of the 2024 “Best Law Firms” by U.S. News & World Report and Best Lawyers®.

Williamson Health Law is ranked Metropolitan Tier I-Detroit in Health Care Law. This is the ninth consecutive year Williamson Health Law has been ranked by Best Lawyers®.

Firms included in the 2024 “Best Law Firms” list are recognized for professional excellence with persistently impressive ratings from clients and peers. Receiving a tier designation reflects the high level of respect a firm has earned among other leading lawyers and clients in the same communities and the same practice areas for their abilities, their professionalism and their integrity.

Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, is also listed in The Best Lawyers in America® 2024. Ms. Williamson has been featured in the Best Lawyers listings since 2013, including recognition in 2022 as The Best Lawyers in America © Lawyer of the Year in Health Care Law in Detroit.

Williamson Health Law Attorney Named to The Best Lawyers in America © 2024

August 17, 2023

Deborah J. Williamson, founder and managing partner of Williamson Health Law, has been selected for The Best Lawyers in America© 2024 for her work in health care law.

Selection for this award denotes legal excellence in the specific practice area.  Since it was first published in 1983, Best Lawyers has become universally regarded as the definitive guide to legal excellence. Because Best Lawyers is based on an exhaustive peer-review survey in which more than 50,000 leading attorneys cast votes on the legal abilities of other lawyers in their practice areas, and because lawyers are not required or allowed to pay a fee to be listed, inclusion in Best Lawyers is considered a singular honor. Corporate Counsel magazine has called Best Lawyers “the most respected referral list of attorneys in practice.”

Williamson Health Law was founded in 2014 by Deborah J. Williamson, who has over 25 years of experience with the legal and compliance issues affecting health care providers, payers and businesses. Williamson Health Law legal services include handling health care corporate and transactional matters, drafting and negotiating health care contracts, counseling on Stark Law and Anti-Kickback Statute compliance, performing regulatory analysis, advising on HIPAA breaches and compliance, appealing payer audits and overpayment demands, handling provider and payer disputes, defending professional license complaints, drafting and counseling on the implementation of compliance plans, and other legal services required by the health care i

Attorney Deborah J. Williamson Named To 2023 Michigan Super Lawyers © List

WHL / August 11, 2023

Williamson Health Law founder and managing partner Deborah J. Williamson has been named to the 2023 Michigan Super Lawyers © list for her work in health care law.

Super Lawyers is a rating service of outstanding lawyers from more than 70 practice areas who have attained a high-degree of peer recognition and professional achievement. The selection process includes independent research, peer nominations and peer evaluations.  Only 5% of lawyers in Michigan have been recognized by Super Lawyers in this annual publication.

Williamson Health Law was founded in 2014 by Deborah J. Williamson, who has over 25 years of experience with the legal and compliance issues affecting health care providers, payers and businesses. Williamson Health Law legal services include handling health care corporate and transactional matters, drafting and negotiating health care contracts, counseling on Stark Law and Anti-Kickback Statute compliance, performing regulatory analysis, advising on HIPAA breaches and compliance, appealing payer audits and overpayment demands, handling provider and payer disputes, defending professional license complaints, drafting and counseling on the implementation of compliance plans, and other legal services required by the health care industry.

Deborah J. Williamson included in DBusiness Magazine’s 2023 list of Top Lawyers

December 23, 2022

Williamson Health Law ranked one of 2023 “Best Law Firms” in Health Care Law by U.S. News & World Report and Best Lawyers®

November 3, 2022

Williamson Health Law has been recognized as one of the 2023 “Best Law Firms” by U.S. News & World Report and Best Lawyers®.

Williamson Health Law is ranked Metropolitan Tier I-Detroit in Health Care Law. This is the eighth consecutive year Williamson Health Law has been ranked by Best Lawyers®.

Firms included in the 2023 “Best Law Firms” list are recognized for professional excellence with persistently impressive ratings from clients and peers. Receiving a tier designation reflects the high level of respect a firm has earned among other leading lawyers and clients in the same communities and the same practice areas for their abilities, professionalism and integrity.

Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, is also listed in The Best Lawyers in America® 2023, an honor that follows Ms. Williamson’s recognition in 2022 as The Best Lawyers in America © Lawyer of the Year in Health Care Law in Detroit. Ms. Williamson has been featured in the Best Lawyers listings since 2013.

Williamson Health Law Attorney Named to The Best Lawyers in America © 2023

October 16, 2022

Deborah J. Williamson, founder and managing partner of Williamson Health Law, has been selected for The Best Lawyers in America© 2023 for her work in health care law.

 Selection for this award denotes legal excellence in the specific practice area.  Since it was first published in 1983, Best Lawyers has become universally regarded as the definitive guide to legal excellence. Because Best Lawyers is based on an exhaustive peer-review survey in which more than 50,000 leading attorneys cast votes on the legal abilities of other lawyers in their practice areas, and because lawyers are not required or allowed to pay a fee to be listed, inclusion in Best Lawyers is considered a singular honor. Corporate Counsel magazine has called Best Lawyers “the most respected referral list of attorneys in practice.”

 This honor follows Ms. Williamson’s recognition in 2022 as The Best Lawyers in America © Lawyer of the Year in Health Care Law in Detroit.  Honorees receive Lawyer of the Year based on their extremely high overall feedback for their professional excellence by their peers in the legal industry.

 Williamson Health Law was founded in 2014 by Deborah J. Williamson, who has over 25 years of experience with the legal and compliance issues affecting health care providers, payers and businesses. Williamson Health Law legal services include handling health care corporate and transactional matters, drafting and negotiating health care contracts, counseling on Stark Law and Anti-

Attorney Deborah J. Williamson Named To 2022 Michigan Super Lawyers © List

WHL / September 5, 2022

Williamson Health Law founder and managing partner Deborah J. Williamson has been named to the 2022 Michigan Super Lawyers © list for her work in health care law.

Super Lawyers is a rating service of outstanding lawyers from more than 70 practice areas who have attained a high-degree of peer recognition and professional achievement. The selection process includes independent research, peer nominations, and peer evaluations. 

Only 5% of lawyers in Michigan have been recognized by Super Lawyers in this annual publication.

Williamson Health Law was founded in 2014 by Deborah J. Williamson, who has over 25 years of experience with the legal and compliance issues affecting health care providers, payers, and businesses. Williamson Heal

Deborah J. Williamson included in DBusiness magazine’s 2022 list of Top Lawyers

December 5, 2021

We’re proud to announce that Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, was selected by a vote of her peers to be included in DBusiness magazine’s 2022 list of Top Lawyers.

 This esteemed list is published in the November/December 2021 issue of DBusiness magazine and online at www.dbusiness.com.

 A lawyer’s inclusion as a 2022 Top Lawyer is based on the peer ratings of fellow attorneys.

Deborah J. Williamson included in DBusiness magazine’s 2022 list of Top Lawyers

November 15, 2021

We’re proud to announce that Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, was selected by a vote of her peers to be included in DBusiness magazine’s 2022 list of Top Lawyers.

This esteemed list is published in the November/December 2021 issue of DBusiness magazine and online at www.dbusiness.com.

A lawyer’s inclusion as a 2022 Top Lawyer is based on the peer ratings of fellow attorneys.

Williamson Health Law ranked one of 2022 “Best Law Firms” in Health Care Law by U.S. News & World Report and Best Lawyers®

November 4, 2021

Williamson Health Law has been recognized as one of the 2022 “Best Law Firms” by U.S. News & World Report and Best Lawyers®.

Williamson Health Law is ranked Metropolitan Tier I-Detroit in Health Care Law. This is the seventh consecutive year Williamson Health Law has been ranked by Best Lawyers®.

Firms included in the 2022 “Best Law Firms” list are recognized for professional excellence with persistently impressive ratings from clients and peers. Receiving a tier designation reflects the high level of respect a firm has earned among other leading lawyers and clients in the same communities and the same practice areas for their abilities, their professionalism and their integrity.

Deborah J. Williamson, Founder and Managing Partner of Williamson Health Law, is also listed in The Best Lawyers in America® 2022. Ms. Williamson has been featured in the Best Lawyers listings since 2013.

Introduction: Five laws for new physicians to know

j / September 21, 2021

There are no balloons, handshakes or smiles when the Office of the Inspector General at the U.S. Department of Health and Human Services welcomes new physicians. There is instead a dry, fairly formal listing of “the five most important Federal fraud and abuse laws that apply to physicians”:

  • False Claims Act
  • Anti-Kickback Statute
  • Physician Self-Referral Law (Stark law)
  • Exclusion Authorities
  • Civil Monetary Penalties Law

“As you begin your career, it is crucial to understand these laws not only because following them is the right thing to do, but also because violating them could result in criminal penalties” and more, the OIG says. The “more” includes fines, exclusion from Medicare and Medicaid and the loss of your medical license.

The False Claims Act

The OIG notes that it’s illegal to submit claims to Medicare or Medicaid that you know – or should know – are false or fraudulent. Penalties for violating the False Claims Act can mean fines of up to three times the amount the programs lost due to your false claims, plus $11,000 per claim you filed.

That means that if Doctor A filed 100 false Medicare claims for $1,000 each, the loss to that program would be $100,000. That means Doctor A could be fined up to $300,000, plus an additional $1,100,000 for his violations.

If Doctor A’s false claims were the results of kickbacks or were made in violation of the Stark law, there can be additional liability under the Anti-Kickback S

3 Michigan doctors and nurse practitioner resolve Medicare fraud allegations

m.metzger@thomsonreuters.com / September 10, 2021

Federal prosecutors and law enforcement agents continue to show that they place allegations of Medicare fraud high on their list of priorities.

Fast as a click

The U.S. Attorney’s office in the Western District of Michigan has announced the results of a Medicare fraud sting called “Operation Happy Clickers”, which has resulted so far in civil suits against three Michigan doctors and a guilty plea by a nurse practitioner. The name of the operation refers to the speed at which the involved medical professionals clicked on and approved prescriptions with little or no review. The prescriptions at issue were for various medical equipment and genetic tests that were not actually medically necessary.

The US Attorney’s Office said the actions resolved allegations of Medicare fraud that totaled $7.3 million.

Operation Happy Clickers follows nationwide arrests in 2019 and 2020 of what were called large-scale Medicare fraud schemes involving telemarketers, durable medical equipment supply company owners and cancer genetic testing labs.

How the alleged scheme worked

In the recent Michigan case, telemarketers (often in overseas call centers) contacted Medicare recipients to sell them medically unnecessary tests and devices. The marketers then allegedly paid healthcare professionals to sign device and test orders. Then the telemarketers allegedly sold the approved orders to companies that supply devices and labs that perfo

Attorney Deborah Williamson named 2022 Lawyer of the Year

gary.tandberg@thomsonreuters.com / August 19, 2021

We’re proud to announce that Williamson Health Law founder and managing partner Deborah J. Williamson has been named one of the Best Lawyers in America in the Health Care Law category.

The accolades don’t end there, however. Because of the “extremely high voter feedback” from her peers, Ms. Williamson has also been named 2022 “Lawyer of the Year” for Health Care Law in Detroit.

Only one attorney in each practice area and community can receive the “Lawyer of the Year” award.

Peer approval

“Recognition by Best Lawyers is based entirely on peer review,” the company says on its website.

The recognition process begins with a nomination. Anyone can make a nomination, but Best Lawyers says only attorneys can give the “meaningful and substantive evaluations of the quality of legal services” that determine who will be honored.

After the peer review process concludes, Best Lawyers reviews the feedback and then checks to make sure that candidates are in good standing with the applicable bar association.

Later, the company notifies the attorneys who have sufficient peer approval to be recognized as among the Best Lawyers in America.

Special recognition

Those candidates who receive “the highest overall peer-feedback for a specific practice area and geographic region” receive even higher recognition as Lawyer of the Year.

We’re proud that Attorney Williamson continues to earn the respect of he

Healthcare system and cardiologist settle whistleblower lawsuit for $37.5 million

gary.tandberg@thomsonreuters.com / August 16, 2021

Last year, the United States spent more than $700 billion to provide Medicare benefits for people age 65 and above. It is important for Michigan physicians and health system management to understand that an investment of that size is going to be protected by federal law enforcement agencies.

One of their most powerful protection tools is the Anti-Kickback Statute, which prohibits paying, offering, soliciting or receiving compensation to induce patient referrals for services covered by Medicare, Medicaid or Tricare.

Entitled to share the settlement

Another powerful tool: whistleblower lawsuits filed by private citizens on behalf of the government involving allegations of fraud against federal programs such as Medicare. The plaintiff can be entitled to a portion of a settlement resolving the matter.

The Department of Justice recently settled a whistleblower lawsuit for what “appears to be the largest settlement in a case brought against a hospital for kickbacks paid to a single physician,” an attorney representing the plaintiff said.

Sizable settlement

According to a MedPage Today report, Prime Healthcare, its CEO and a cardiologist employed by the California-based health system will pay $37.5 million to settle a whistleblower lawsuit that alleged kickbacks and fraudulent medical billing.

Prime Healthcare CEO and founder Prem Reddy, MD, and the system he headed allegedly arranged in 2015 to buy from

Attorney Deborah Williamson honored by Super Lawyers

deborahwilliamson / August 4, 2021

Williamson Health Law is pleased to announce that firm founder and managing partner Deborah J. Williamson has been named to the 2021 Michigan Super Lawyers list in the Health Care Law category.

First-rate in each state

Super Lawyers annually rates outstanding attorneys in each state in more than 70 practice areas.

Attorneys with high levels of peer recognition and professional achievement can be nominated by either fellow lawyers or by attorney-led research teams.

A dozen criteria are then used to evaluate nominees, including experience, verdicts/settlements, education, pro bono work/community service, special licenses/certifications and professional honors and awards.

A bit of background

With more than two decades of experience representing health care providers in legal and compliance matters, Ms. Williamson is respected by clients and peers alike.

She regularly speaks and writes on important health care law topics such as the Stark Law, HIPAA, regulatory compliance plans and post-payment audits.

She also serves on the Council of the State Bar of Michigan’s health care law section and is a member of the American Health Law Association.

Ms. Williamson graduated magna cum laude from the Michigan State University College of Law in 1997 and was honored as one of the legal profession’s Rising Stars in 2011-12.

Part II: the perils of social media for doctors

deborahwilliamson / July 23, 2021

Regular readers of our Michigan Health Care Legal Blog will undoubtedly recall a recent post detailing potential pitfalls for physicians on social media. The post included useful information about going viral, violating patient privacy and advice for how to deal with patients’ “friend” requests on Facebook.

In this post, we’ll delve into the dispensing of specific medical advice, and making unprofessional comments and posting photos of unprofessional behavior on social media.

Specific medical advice

When you post general comments about treatments or conditions, there will often be responses asking for advice about their specific case. A reply or back-and-forth comments could be a HIPAA violation. It’s also possible that a reply could be construed as a physician-patient relationship.

The doctor who wrote a Medscape article about social media advised physicians who get requests for advice to urge the person to visit your practice.

It might also be a good idea to include on your social media pages a boilerplate statement that you won’t comment on social media on any individual’s specific case.

Unprofessional behavior

There are doctors who have made unprofessional comments or shared photos of unprofessional behavior on social media platforms. They don’t seem to understand that patients and employers can view the posts and that there can be serious consequences for flaunting unprofessional conduc

The perils of social media for doctors

deborahwilliamson / July 21, 2021

Social media is as ubiquitous for Michigan physicians as it is for everyone else. Some people wake up to Twitter and go to sleep with Facebook. In between, they steal away moments with Snapchat, Instagram, Reddit, Pinterest and others.

Doctors need to be especially careful on social media, always mindful of protecting patient privacy and when sharing medical information, always presenting absolutely correct info.

Some physicians stay away from social media because of its risk of potential disaster. But a California doctor wrote in Medscape that you don’t need to abandon social media. You simply need to exercise discretion and understand its risks.

Going viral

Social media amplifies your words and images. A stray comment can go viral and reach hundreds of thousands of people (and even more). Mistakes and misstatements are difficult to undo. You can take down an ill-advised Facebook comment and delete a cringe-worthy tweet, but both can live on after being shared or in screenshots.

Think through your comments before posting them. There can sometimes be a heavy price to pay for being clever, bold or controversial.

Violations of patient privacy

Social media has a nearly infinite supply of opportunities for doctors to violate patient privacy. Examples: citing patients’ cases on the practice’s website, crowdsourcing a patient’s diagnosis with colleagues and posting photos that inadvertently reveal a patie

Common coding errors to avoid

deborahwilliamson / July 17, 2021

We read recently of a radiation therapy provider that agreed to pay more than $3.5 million in a CMP (civil monetary penalty) settlement with the OIG (Office of Inspector General).

According to the settlement, the company submitted claims for radiation and oncology services that:

  • Used incorrect CPT codes and service dates
  • Weren’t provided
  • Didn’t include sufficient documentation to support service necessity
  • Were “unbundled”
  • Contained “incomplete documentation”
Fraud or abuse

In general, the AMA says, medical billing errors fall into one of two broad categories: fraud or abuse.

The AMA’s “Principles of CPT Coding” offers definitions of the terms: Fraud “involves intentional misrepresentation,” while abuse means “the falsification was an innocent mistake, but nonetheless representative.”

Common coding miscues to avoid

The organization also lists some common medical-coding errors to avoid:

  • Unbundling codes: the AMA says providers should use the single code “that captures payment for the component parts of a procedure.” Don’t unbundle to increase payments.
  • Upcoding: consequences for this can be “severe.”
  • Failing to check NCCI edits before reporting multiple codes
  • Failure to append appropriate modifiers/a

Referrals and the trouble they can cause in healthcare

gary.tandberg@thomsonreuters.com / July 1, 2021

In some industries, it’s not only legal to reward someone who refers business, it’s considered good form to do so. Healthcare is not one of those industries, however. It’s a crime for healthcare practitioners to take anything of value in return for a referral, order or prescription when the goods or services are paid for by Medicare, Medicaid or any other part of the federal government.

Beaumont Health settlement

Many Detroit-area healthcare providers undoubtedly recall that in 2019, Beaumont Health agreed to settle allegations that it violated the Anti-Kickback Statute by making payments to physicians who made referrals to its William Beaumont Hospital in Royal Oak.

The health system was also accused of violating the Stark Law, or self-referral law, which prohibits hospitals from billing Medicare for services referred by physicians with whom the hospital has a financial relationship.

Beaumont Health agreed to pay $82.74 million to the federal government and another $1.76 million to the state of Michigan.

EHS-related case

Another application of the Anti-Kickback law can be found in the recent settlement of the CareCloud Health case. The Florida-based developer of EHR (electronic health records) “agreed to pay $3,806,966.70 to resolve allegations that it paid unlawful kickbacks to generate sales of its EHR products,” th

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