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In 1977, Ms. Stiller helped to structure a settlement between a nursing home chain and the state Department of Health to take into account provisions of the 1977 Medicare/Medicaid Anti-Fraud & Abuse Amendments — which hadn't even passed Congress yet at that point.
In 1985, when the U.S. Court of Appeals for the Third Circuit issued the monumental Greber decision articulating the "one purpose" test that was to be the basis for the expansive reading of the Anti-Kickback Law embraced by federal enforcement agencies, Ms. Stiller's clients were among the first healthcare providers to receive warning of that development. In 1991, when the first Safe Harbor regulations came out, Ms. Stiller co-authored a well-received nationally published summary of them.
Over the years, as Congress has passed more laws, courts have issued new interpretations, and federal and state agencies have published more regulations, Ms. Stiller has been there to assist healthcare providers with staying in compliance. Her work in this area includes:
- Advice concerning fraud and abuse and Stark Law implications of
business transactions
- Structuring hospital donations of electronic health records technology to physicians so as to fit within Stark Law exceptions and Anti-Kickback Law safe harbors.
- Development and implementation of corporate compliance plans
- Compliance with HIPAA privacy and security regulations
- Representation of clients in administrative enforcement proceedings
- Advice on what to do when a problem is discovered
- Self-disclosure protocols
- OIG advisory opinions
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