Clinical Research Billing & Compliance. September 2010. Executive Memorandum.
Source: CMS Transmittal AB-00-89
* Exclusion from government contracting, subcontracting or involvement in procurement programs can also be imposed
Note: data prior to 2007 was not being tracked with any regularity.
Thank you for your advice and guidance!Mat InnesBenjie JohnsonAndree JoyauxMelissa KarjalaJack KufahlSarah KyleKim LeppertAnna LokJill MalayangTom MarksJim MaszaticsBrett MillerAmy Milliman
Shari Barnett Mary Hill Samya Nasr
Rick Bluhm Glen Hiller Sandy O’Holleran
Kerri Briesmiester Mei-Lan Huang Carolyn Pappas
David Browning Rebecca Hughes Paulina Radenbaugh
John Burnett Judy Rotthoff
Maria Ceo Marifelice Roulo
Karis Crawford Tom Shanley
Sarah Faix Nan-Sheng Sheng
Mary Greer Jane Sierra
Jaimee Gauthier Sam Silver
Steve Gendler Monica Stiddom
Debbie Gipson Karen Strode
David Golden Gina Vuocolo-Branch
Teri Grieb Mariella Wells
Cathy Handyside Peg White
Jan Hewett Sandy Wilcock
Note: Draft versions accepted and satisfactory for CRAO review
(a) Any person who…
(1) knowingly presents, or causes to be presented, to an officer or employee of the United States Government or a member of the Armed Forces of the United States a false or fraudulent claim for payment or approval;
(2) knowingly makes, uses, or causes to be made or used, a false record or statement to get a false or fraudulent claim paid or approved by the Government;
(3) conspires to defraud the Government by getting a false or fraudulent claim paid or approved by the Government
is liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000, plus 3 times the amount of damages which the Government sustains because of the act of that person . . . .
Very High Risk
Pub. 100-04, Transmitttal:1418, January 18, 2008, Change Request:5805 Effective Date January 1, 2008.