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Establishing and implementing necessary structure and procedures
Medicare Compliance Officer advice and consultation
Coordination and cooperation with in-house counsel
Ongoing consultation on a retainer basis
Updating policies, procedures, and forms to meet changing regulatory requirements
Liaison and routine dealings with CMS
Medicare Compliance and Quality Improvement Committee
Performance oversight and Reporting-Legal Issues
Fraud, Waste, and Abuse Policies and Procedures and Control Programs
CMS Monitoring and Reporting Issues
State/Federal Regulatory Issues
Coordination and cooperation
with in-house counsel
The CMS Compliance Counsel Department of the firm is willing to adapt its services to coordinate with the in-house counsel of its clients, considering the varied structures and composition of legal departments within various corporate entities. The firm will adapt its services to meet the needs of the clients, whether a large insurer with dozens of attorneys in a well-structured, centralized, general counsel's office, or a small insurer with a few attorneys who operate under a loosely structured corporate framework, or with various groups of counsel in different locations. In this context, we believe that the size of the firm is an advantage, because we are not so rigid as law firms which are overly structured and laden with multiple layers of partners, junior partners, senior associates, associates, and law clerks.
Nevertheless, it is critical from a compliance standpoint that the firm be independent of the General Counsel's office, or established in-house or general corporate counsel, to assure adherence to the independence of the Medicare Compliance Officer function and the Medicare Compliance Oversight Committee. Therefore, the firm will at all times follow applicable regulatory and ethical requirements for independence and reporting.