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Law Office of Markus P. Cicka, LLC

How We Helped Our Clients Through Our Legal Services

Presentations

“Complying With the Conditions of Participation: How to Avoid Top Survey Citations”

Markus P. Cicka presented to the Illinois HomeCare & Hospice Council’s Annual Conference | Chicago, Illinois | March 4, 2020.

“The OIG Is Loosening Up: Providing Free Services Within Legal Parameters” 

Co-Presented With Jeff Baird to the American Association for Homecare (via Webinar) | August 20, 2019

“Kickbacks, Inducements, False Claims, and Other Fraud Landmines to Avoid”

Co-Presented With Jeff Baird to the American Association for Homecare (via Webinar) | June 26, 2019

“Managed Care Contracts: How to Negotiate in Your Favor”

Co-Presented With Pam Colbert to the Medtrade Spring Conference | Las Vegas, Nevada | April 17, 2019

“Accessing Another Supplier’s Contract: Working With Manufacturers, Patient Incentive Programs, and Other Arrangements”

Co-Presented With Todd Moody to Medtrade Spring Conference | Las Vegas, Nevada | April 16, 2019

“‘Hub and Spoke,’ Centralized Intake, and Other Steps to Streamline Operations”

Co-Presented With Jeff Baird to the American Association for Homecare (via Webinar) | January 15, 2019

“Cultivating a Culture of Compliance Following the Sarbanes Oxley Act”

Presented to LeadingAge Annual Meeting and Expo | Nashville, Tennessee –|October 19, 2014

“A Guide to Medicare Payment Suspensions”

Presented to the Missouri Association of Rural Health Clinics Fall

Conference | Lake of the Ozarks, Missouri | October 7, 2014

“The 2014 OIG Workplan – Home Health and Medicare Suspension of Payments”

Presented to the Missouri Council for In-Home Services" | Lake of the Ozarks, Missouri | September 16, 2014

“The 2014 OIG Workplan – Home Health and Medicare Suspension of Payments” 

Presented to the Missouri Council for In-Home Services Annual Conference | Lake of the Ozarks, Missouri | September 16, 2014

“How to Negotiate Your First Employment Contract After Residency”

Presented to St. Louis University Residents Association | St. Louis, Missouri | September 9, 2014

“The Importance of a Compliance Program in Healthcare” 

Presented to Midwest Health Care, Inc.’s RHC Billing Training Seminar for Provider-Based and Independent Clinics | Cape Girardeau, Missouri | May 13, 2014

“An Overview of RAC Audits of DME Providers”

Presented to the MO HealthNet DME Advisory Board | Jefferson City, Missouri | April 30, 2013

“An Update From the Missouri Medicaid Audit and Compliance Unit” 

Presented to the Missouri Association of Osteopathic Physicians and Surgeons House of Delegates Conference | Lake of the Ozarks, Missouri | April 24, 2013

“Overview of the Missouri Medicaid Audit and Compliance Unit” 

Presented to the ADP CDS Vendor Resource Conference | St. Louis, Missouri | March 14, 2013

“An Update From the Missouri Medicaid Audit and Compliance Unit" 

Presented to the Missouri Coalition of Community Mental Health Centers | Jefferson City, Missouri | March 13, 2013

“Detecting and Preventing Fraud and Abuse in Medicaid Managed Care Plans”

Presented to the Medicaid Innovations Forum | Orlando, Florida | February 7, 2013

“Medicaid Fraud”

Presented to the Missouri House of Representatives Appropriations Committee on Health, Mental Health and Social Services | Jefferson City, Missouri | January 29, 2013

“Best Practices in Case File Development”

Presented to the "Interactions Between Medicaid Fraud Control Units and Program Integrity Units" Symposium | Medicaid Integrity Institute | Columbia, South Carolina | January 23, 2013

“Medicaid Program Integrity Issues – RACs and MICs”

Presented to the Seventh National RAC (and MAC) Summit | Washington, DC | December 5, 2012

“Question and Answer Session”

With the Missouri Centers for Independent Living | Jefferson City, Missouri | November 5, 2012.

“An Overview of the Missouri Medicaid Audit and Compliance Unit and the RAC” 

Presented to the BJC Compliance Forum | St. Louis, Missouri | October 30, 2012

“An Overview of the Medicaid Recovery Audit Contractor (RAC) Program”

Presented to the Missouri Medical Management Association Monthly Meeting | Cape Girardeau, Missouri | October 24, 2012

"Enrollment and Screening of Providers"

Presented to the 2012 Annual Conference of the Missouri Association of County Developmental Disability Services | Lake of the Ozarks, Missouri | October 11, 2012

“The Detection of Medicaid Fraud, Waste and Abuse”

Presented to the 43rd Annual LeadingAge Missouri Conference | Lake of the Ozarks, Missouri – September 27, 2012

“Preparing for Medicaid Audits”

Presented to the Missouri Council for In-Home Services | Lake of the Ozarks, Missouri | September 11, 2012

“Auditing Consumer Directed Services and In-Home Services Providers”

Presented to the Services for Independent Living Monthly Meeting | Jefferson City, Missouri | July 2, 2012

“Medicaid Audits of Missouri Department of Mental Health Providers”

Presented to the Missouri Association of County Developmental Disabilities Services | Lake of Ozarks, Missouri | June 27, 2012

“Medicaid Audits of In-Home Services”

Presented to the Missouri Council for In-Home Services | Jefferson City, Missouri | June 20, 2012

“Coordinating Medicaid Audits: RAC, MIC, and OIG”

Presented to the National Medicare-Medicaid Payment Incentives and Penalties Summit | Arlington, Virginia | May 31, 2012

“An Overview of Missouri Medicaid Audit and Compliance and Auditing Adult Day Care Facilities”

Presented to the Missouri Adult Day Services Annual Conference | Lake of the Ozarks, Missouri | May 4, 2012

“Missouri Medicaid Audit and Compliance and Auditing Physician Practices”

Presented to the Missouri Association of Osteopathic Physicians and Surgeons 114th Missouri Osteopathic Annual Convention | Lake of the Ozarks, Missouri | May 3, 2012

“Missouri Medicaid Audit and Compliance”

Presented to the Missouri Alliance for Home Care Annual Conference and Home Care Exhibition | Lake of the Ozarks, Missouri |

April 25, 2012

“Missouri Medicaid Audit and Compliance”

Presented to the Missouri Assisted Living Association Spring Meeting | Branson, Missouri, April 24, 2012

“Overview of the Missouri Recovery Audit Contractor (RAC) Program”

Presented to the American Association of Healthcare Administrative Management – Missouri Hawthorn Chapter #8 | Jefferson City, Missouri | April 20, 2012

“Overview of the Missouri Recovery Audit Contractor (RAC) Program”

Presented to the Healthcare Information and Management Systems Society – Midwest Gateway Chapter's 2012 Force of Data Anthology for Missouri Hospitals Meeting | Rolla, Missouri | March 8, 2012

“Missouri Medicaid Audit and Compliance”

Presented to the Missouri Association of Public Administrators (Mini-Training) | Clarence, Missouri | February 29, 2012

“Overview of the Missouri Recovery Audit Contractor (RAC) Program”

Presented to the Healthcare Financial Management Association's Ethics, Compliance and Regulatory Conference | Springfield, Missouri | February 24, 2012

“Missouri Medicaid Audit and Compliance”

Presented to the Missouri Bar's 2011 Annual Government Practice Institute | Jefferson City, Missouri, December 2, 2011

“Overview of the Missouri Recovery Audit Contractor (RAC) Program”

Presented to the Missouri Alliance for Home Care Board of Directors' Meeting | Jefferson City, Missouri | February 9, 2012

“Missouri Medicaid Audit and Compliance: Suspension of Medicaid Payments"

Presented to the Missouri Bar's Health and Hospital Law Committee | Jefferson City, Missouri | November 18, 2011

“Missouri Medicaid Audits and Investigations: Compliance Ideas and Strategies”

Presented to Missouri Society of Health Care Attorneys | Lake of the Ozarks, Missouri, November 10, 2011

“Overview of Missouri Medicaid Audit and Compliance and the Detection of Fraud, Waste, and Abuse”

Presented to the Saint Louis College for Health Careers | St. Louis, Missouri | August 5, 2011

“Overview of Missouri Medicaid Audit and Compliance”

Presented to the MO HealthNet Oversight Committee | Jefferson City, Missouri | June 7, 2011

"Overview of Missouri Medicaid Audit and Compliance and the Recovery Audit Contractor (RAC) Program"

Presented to Thompson Coburn, LLP | St. Louis, Missouri | May 31, 2011

“Overview of Missouri Medicaid Audit and Compliance and the Recovery Audit Contractor (RAC) Program”

Presented to Healthcare Financial Management Association – Annual Joint Spring Conference | Saint Louis, Missouri | May 19, 2011

Testified Before the Missouri House Judiciary Subcommittee on the Proposed measure to Establish a False Claims Act for Missouri | March 9, 2011

“What Your State Medicaid Director Should Have Told You”

Presented to the Medicaid Integrity Institute – Program Director’s Meeting – National Advocacy Center | Columbia, South Carolina | December 2010

“Medicaid Provider Enrollment and Termination/Exclusions”

Presented to Saint Louis Area Health Lawyers’ Association | St. Louis, Missouri | October 2010

“MO HealthNet: Custom Program and Policy Analysis”

Presented to National Association for Medicaid Program Integrity | New Orleans, Louisiana | September, 2010

“Overview of Medicaid's Program Integrity, DME, and Home Health Programs”

Presented to Bryan Cave LLP | September 2010

“Program Integrity and Program Integrity's Relationship with the Medicaid Fraud Control Unit”

Presented to Polsinelli Shughart PC | June 2010

“Program Integrity, Cost Recovery and the Medicaid Integrity Program”

Presented to the Missouri Society of Health Care Attorneys – April 2010

Publications




Markus P. Cicka prepared "DMEPOS: Back to Basics - You Need More Than One Billing Number If You Are Serving Medicare Patients In Multiple Locations", January 1, 2020. Link.


Markus P. Cicka prepared "Home Health Value-Based Purchasing Model Results Released", December 28, 2020. Link.


Markus P. Cicka prepared "Medicare Telehealth Services: Where to Check If an Address Is Eligible for Medicare Telehealth Originating Site Payment", December 27, 2020. Link.


Markus P. Cicka prepared "Medicare Telehealth Services: Here's Where To Find A List of Services Payable", December 26, 2020. Link.


Markus P. Cicka prepared "DMEPOS: Back to Basics - Pharmacies - Get Accredited or Get Exempted", December 23, 2020. Link.


Markus P. Cicka prepared "Are You Billing Correctly For Polysomnography (Sleep Studies)?" December 22, 2020. Link.


Markus P. Cicka prepared "Home Health Care Owner Sentenced for Defrauding Medicaid: What Did the Government Allege?" December 21, 2020. Link.


Markus P. Cicka prepared "DMEPOS: Back to Basics - Round 2021 Competitive Bidding Winners Announced", December 20, 2020. Link.


Markus P. Cicka prepared "Medicaid Targeted Case Management: What Is it?" December 19, 2020. Link.

Markus P. Cicka prepared "Are You Ready to Enroll As A Home Infusion Therapy Supplier?", December 18, 2020. Link.


Markus P. Cicka prepared "CMS Proposes Changes to Coverage and Payment Policies For External Infusion Pumps and Continuous Glucose Monitors", December 16, 2020. Link.


Markus P. Cicka prepared "Four Physicians and a Biller Convicted of Home Health Care Fraud: What Did the Government Allege?" December 15, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Are You Properly Billing for Continuous Glucose Monitors?" December 14, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Are You Properly Billing for Home Glucose Monitors?" December 12, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - What Is Competitive Bidding?" December 11, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Competitive Bidding (Deficiencies in Financial Documents)" December 10, 2020. Link.

Markus P. Cicka prepared "Illinois Medicaid Telemedicine Payments", December 9, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - What Does 'Providing Access to Documentation' Mean?" December 7, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Capturing A Beneficiary's IP Address Is Not Enough To Meet Supplier Standard 11", December 6, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - What Services Can a DME Supplier Sub-Contract To Another Entity?" December 5, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - What Happens When An Oxygen Supplier Wants to Exit Its Business?" December 4, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Supplier Standard #7 and Permanent Visible Signage", December 3, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - What Happens If A Supplier Is Denied Or Revoked?", December 2, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Changes of Ownership", December 1, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Contracting for Inventory", November 30, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - What Is An Authorized and Delegated Official on  CMS-855s?" November 29, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Enrollment Tip If You Supply In More Than One State", November 28, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Submit Claims Once Within Four Consecutive Quarters", November 27, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Complying with Supplier Standard 16", November 25, 2020.  Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Are You Properly Accredited For Your Products?", November 21, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Reporting Final Adverse Actions", November 20, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - State Licensure Standard". November 16, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Surety Bond Requirements", November 15, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Difference Between an NPI and a PTAN", November 14, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Obtaining an NPI", November 13, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - DMEPOS Accreditation Organizations", November 11, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics - Steps to Enroll As a DMEPOS Supplier", November 7, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment:  The National Supplier Clearinghouse - COVID19 Information", November 4, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment:  Back to Basics - Face-To-Face Encounter Requirement for Certain Durable Medical Equipment", October 31, 2020. Link.


Markus P. Cicka prepared "OIG Audit Critical of Hospital Inpatient Claims with Post-Acute-Care Transfers to Home Health Services", October 29, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 16 - Medicare Quality Standards -Supplier Product-Specific Service Requirements [Respiratory Equipment, Services and Supplies])", October 27, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 16 - Medicare Quality Standards -Supplier Product-Specific Service Requirements [Follow-Up])", October 25, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 15 - Medicare Quality Standards -Supplier Product-Specific Service Requirements [Training and Instructions])", October 23, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 14 - Medicare Quality Standards -Supplier Product-Specific Service Requirements [Delivery and Set-Up])", October 22, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 13 - Medicare Quality Standards -Supplier Product-Specific Service Requirements [Intake and Assessment])", October 21, 2020. Link.


We are on Twitter!  Socialize With Us!  Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 12 - Medicare Quality Standards -Supplier Business Services Requirements [Information Management])", October 20, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 11 - Medicare Quality Standards -Supplier Business Services Requirements [Product Safety])", October 19, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 10 - Medicare Quality Standards -Supplier Business Services Requirements [Performance Management])", October 18, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 9 - Medicare Quality Standards -Supplier Business Services Requirements [Consumer Services])", October 17, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 8 - Medicare Quality Standards - Supplier Business Services Requirements [Human Resources Management])", October 16, 2020.  Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 7 - Medicare Quality Standards - Supplier Business Services Requirements [Financial Management])", October 15, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 6 - Medicare Quality Standards - Supplier Business Services Requirements [Administration])", October 14, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 5 - Medicare Accreditation)", October 13, 2020.  Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 3 - Medicare Surety Bond Requirements)", October 12, 2020. Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 3 - Medicare Requirements of Participation)", October 11, 2020.  Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 2 - Medicare Coverage)", October 10, 2020.  Link.


Markus P. Cicka prepared "Home Medical Equipment: Back to Basics (Part 1 - State Licensure)", October 9, 2020.  Link.


#1stTalkCompliance - Catherine Short speaks with a St. Louis healthcare attorney, Markus P. Cicka, J.D., LL.M. about “Billing for Chronic Care Management: What Are the Problematic Issues?” The two discuss what is #chroniccaremanagement, having an understanding of who exactly can bill for providing chronic care management services, and discover what recent chronic care management #billing issues have been flagged by the OIG.  September 14, 2020.


Markus P. Cicka prepared "Arbitration and Mediation of Healthcare Disputes: (Part 2 - Mediation)", September 10, 2020.  Link.


Markus P. Cicka prepared "Arbitration and Mediation of Healthcare Disputes: (Part 1 - Arbitration)", September 9, 2020.  Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Voluntary Disclosures of Overpayments (Part 4 - OIG Provider Self-Disclosure Protocol)", September 4, 2020.  Link.


We Are Honored! “We assisted our client, a Georgia-based durable medical equipment supplier, in growing its business by drafting an agreement between our client and another durable medical equipment supplier which allowed the non-client to access our client’s network provider agreement with a commercial insurance carrier.”


We Are Honored! We assisted a New York-based healthcare management company assess agreements between Covered Entities and Contract Pharmacies under the 340B Drug Pricing Program. The 340B Drug Pricing Program is a US federal government program created in 1992 that requires drug manufacturers to provide outpatient drugs to eligible health care organizations and covered entities at significantly reduced prices.


Markus P. Cicka prepared "Fraud and Abuse Laws: Voluntary Disclosures of Overpayments (Part 3 - Stark Law Violations)", September 1, 2020.  Link.


Markus P. Cicka prepared ""Fraud and Abuse Laws: Voluntary Disclosures of Overpayments (Part 2 - Disclosures to MACs)", August 31, 2020.  Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Voluntary Disclosures of Overpayments (Part 1 - Benefits and Risks)", August 30, 2020.  Link.


Markus P. Cicka prepared "The Federal Government Has Issued a Renewed Advanced Beneficiary Notice of Noncoverage Form (ABN), But What Is An ABN for Purposes of a Home Health Agency?" August 29, 2020.  Link.


Markus P. Cicka prepared "Billing Medicare for Orthotic Braces", August 28, 2020.  Link.


Markus P. Cicka prepared "You've Heard of CLIA.  But What Is it?", August 27, 2020.  Link.


We Are Honored! We assisted our client, a Medicaid provider, in having its Medicaid payment suspension lifted. Our actions helped the client stay in business and continue to serve Medicaid patients until a hearing on the merits of the case occurs.


We Are Honored! We assisted an immigrant from the former Soviet Union in obtaining benefits from the Missouri Department of Mental Health (DMH). DMH initially rejected our client’s application for benefits due to an issue pertaining to records possibly located in the former Soviet Union. We provided the evidence DMH required, resulting in DMH reversing its initial denial of benefits.


Markus P. Cicka prepared "The Use of Telemedicine Services by Texas Medicaid Providers", August 26, 2020.  Link.


Markus P. Cicka prepared "Are You Prepared To Correctly Bill for Home Infusion Therapy Services After January 1, 2021?", August 18, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Medicare Appeal Process (Part 6 - Medicare Consent Settlement Procedures)", August 16, 2020.  Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Medicare Appeal Process (Part 5 - Judicial Review in Federal Court)", August 15, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Medicare Appeal Process (Part 4 - Appeal To The Medicare Appeals Council)", August 14, 2020.  Link.

Markus P. Cicka prepared "Fraud and Abuse Laws: Medicare Appeal Process (Part 3 - Review By An Administrative Law Judge)", August 7, 2020. Link.

Markus P. Cicka prepared "Fraud and Abuse Laws: Medicare Appeal Process (Part 2 - Reconsideration By A Qualified Independent Contractor)", August 6, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Medicare Appeal Process (Part 1 - Redetermination)", August 5, 2020. Link.

Markus P. Cicka prepared "Fraud and Abuse Laws: Use of Statistical Sampling In An Audit (Part 2 -Areas to Challenge)", August 4, 2020. Link.

Markus P. Cicka prepared "Fraud and Abuse Laws: Use of Statistical Sampling In An Audit (Part 1 - An Overview)", August 1, 2020.  Link.

Markus P. Cicka's article "Expect Audits After the Emergency Ends" was published by HomeCare magazine, July 31, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Government Requests for Information (Part 4 - What to Expect When the Government Knocks on the Door)", July 27, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Government Requests for Information (Part 3 - Responding To Government Requests for Information)", July 26, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Exclusion of Individuals or Entities (Part 5 - Determining Whether a Person is Excluded)", July 25, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Exclusion of Individuals or Entities (Part 4 - Effect of Exclusions)", July 24, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Government Requests for Information (Part 2 - Procedural Safeguards)", July 15, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws:  Government Requests for Information (Part 1 - Overview)", July 14, 2020.  Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Exclusion of Individuals or Entities (Part 3 - Section 1156 Exclusions)", July 12, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Exclusion of Individuals or Entities (Part 2 - Section 1128 Exclusions)", July 8, 2020. Link.


Markus P. Cicka prepared "Fraud and Abuse Laws: Exclusion of Individuals or Entities (Part 1 - The Process)", July 1, 2020.  Link.





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