December 3, 2014
In March 2014, OIG excluded CSHM, LLC (which managed and operated the national chain of Small Smiles Dental Centers) from Medicare, Medicaid and all other federal healthcare programs for at least five years because of its alleged material breaches of its corporate integrity agreement (CIA) with OIG. This case exemplifies the government’s increasing scrutiny of DSOs, which otherwise have grown substantially in popularity in recent years, thanks largely to increased private equity investment.
McGuireWoods attorneys Geoffrey Cockrell, Barton Walker, Amber Walsh, Holly Carnell and John Saran, and summer associate John Harig,a discuss this case in a white paper titled “Compliance Best Practices for Dental Providers: Recent OIG Activity Highlights Need for Robust Compliance Efforts .”
Executive Summary