In March 2014, the U.S. Department of Health and Human Services Office of the Inspector General (OIG) excluded CSHM LLC, which manages and operates the national chain of Small Smiles Dental Centers, from Medicare, Medicaid and all other federal healthcare programs for at least five years, due to alleged material breaches of its corporate integrity agreement with OIG. This case exemplifies the government's increasing scrutiny of DPM companies, which otherwise have become popular in recent years, thanks to increased private equity investment.

McGuireWoods attorneys Geoffrey Cockrell, Holly Carnell and Amanda Enyeart and summer associate John Harig discuss this case in a white paper titled " 7 Key Lessons for Dental Practice Management Companies from Corporate Integrity Agreements." Specifically, they analyze the described enforcement action, as well as guidance formally distributed by the Office of the Inspector General, and distill the information into seven lessons for dental practice management companies:

  1. Establish effective compliance policies and procedures.
  2. Designate an independent compliance officer and compliance committee.
  3. Train and educate staff on compliance.
  4. Continually review the compliance program.
  5. Report and respond to issues effectively and completely.
  6. Monitor and correct any quality of care or medical necessity issues.
  7. Ensure accurate billing and coding for services rendered.

For more explanation of these lessons, see the full text of the white paper.

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