Cape Cod Hospital Settlement Announced – $24.3 million

However, from November 1, 2015, to December 31, 2022, CCH allegedly submitted numerous claims to Medicare for TAVR procedures that did not meet these requirements. In some cases, the evaluations were conducted by an insufficient number of physicians. In others, the physicians failed to document and share their clinical assessments properly.

Medicare permitted coverage for this newly developed cardiac procedure only under certain conditions to ensure patient safety. Cape Cod Hospital ignored those rules and received millions of dollars from Medicare to which it was not entitled. This conduct persisted for years despite internal warnings.  This investigation and settlement ensures that patient safety is prioritized over a hospital’s bottom line.

-Remarks by Acting U.S. Attorney Joshua S. Levy for the District of Massachusetts.

Cape Cod’s Misconduct Revealed by a Whistleblower

CCH’s misconduct was initially brought to light by a former physician at CCH under the qui tam provision of the False Claims Act. The qui tam provisions allow private individuals to file actions on behalf of the United States and share in any financial recovery. In this case, the whistleblower will receive approximately $4.36 million.

Cape Cod Hospital Settlement Includes a Corporate Integrity Agreement

As part of the settlement, CCH signed a five-year corporate integrity agreement with the Department of Health and Human Services, Office of Inspector General (HHS-OIG). The agreement includes an annual review of the hospital’s Medicare claims by an Independent Review Organization to ensure compliance with Medicare rules.

CCH received some leniency in the settlement due to its proactive measures. Specifically, CCH voluntarily disclosed the non-compliance issues, cooperated with the investigation, and took steps to remedy the situation. These actions included producing relevant materials, identifying pertinent medical records, acknowledging its failure to meet Medicare requirements, and implementing corrective measures.

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