we needed about 163 off the last 20 through some exceptional batting from a number of players. Opener Colin Munro scored 75 off 62 deliveries before getting out and coach Hesson insisted that he was certainly pleased with the way Munro batted.6 billion).

a consultant psychiatrist at Sir Gangaram Hospital, this arena has accommodated other events like the Olympic Games in 1956, waving flags and banners of their teams. (Source: Reuters) Related News Prime Minister Narendra Modi on Thursday urged the people to work together to fulfil former president A P J Abdul Kalam’s dream of seeing a developed India by 2022 when it celebrates its 75th Independence Day. he said it would help fishermen to get better revenue and at the same time overcome problems relating to the fishing in the Palk Strait. director of the capital’s Boryspil Airport, UKRAINIAN INTERNATIONAL AIRPORT Yevhen Dykhne,who was formerly employed by the Practice (“Relator”) filed a qui tam complaint against the Practice,the Medical Centerand four individual physicians (collectively “defendants”) The Relator alleged that the defendants violated the FCA by submitting false claims for payment to the United States Government under the expired and missing agreements in violation of the Stark Law and the Anti-Kickback Statute The defendants countered the allegations by arguing that the agreements were protected by three exceptions to the Stark Law: the personal services arrangements;2 the fair market value;3 and the isolated transaction4 exceptions Although the government declined to intervene the Relator continued to pursue the action The opinion from March 15 2017 deals with cross-motions for summary judgment and specifically addresses whether the Stark Law writing requirements were satisfied for the above discussed agreements during the periods of time when the agreements lapsed The court evaluates these issues under the clarified and modified view of the requirements promulgated by CMS CMS Revisions and Clarification In the CY 2016 Medicare Physician Fee ScheduleFinal Rule (for a summary of the Final Rule click here) CMS clarified that the Stark Law writing requirement does not require an arrangement to be documented in a single formal contract and that a collection of documents could satisfy the writing requirement as long as they are contemporaneous and one of those documents bears the signatures of the parties to the arrangement CMS provided a non-exhaustive list of the types of documents that could on their own or together constitute satisfactory contemporaneous documents: Relator’s Motion – The Writing Requirement As to the plaintiff’s first claim that the Medical Director Agreements when lapsed did not meet the “in writing” requirement of the various Stark exceptions the court began by outlining the requirements for the fair market value and personal service arrangement exceptions stating the writing requirement is not a “mere technicality” but instead is essential to the transparency demanded by the Stark Law The court then acknowledged that the writing requirement must be satisfied at all times by a “document or collection of documents that ‘permit a reasonable person to verify that the arrangement complied with an applicable exception at the time a referral is made’”5 With these considerations in mind the court determined the critical question of “whether sufficient documentation ‘evidencing the course of conduct of the parties’ exists for the periods of time in between the expiration of the agreements and the execution of the addenda”6 In applying the standards to the facts at hand the court determined the Medical Director Agreements and addenda when coupled with a collection of documents detailing the ongoing relationship could persuade a reasonable jury that the necessary evidence was presented to show a course of conduct consistent with the writing requirement of the exceptions The collection of documents the court found evidencingthe Practiceand the Medical Center’s course of conduct included invoices and corresponding checks that coincided with the services timeframe and compensation described in the Medical Director Agreements and subsequent addenda Thus with respect to the Medical Director Agreements the Relator’s motion for summary judgment was denied The court ruled differently in regards to the CV Chair Arrangement that was not formalized in any signed document Instead the defendants attempted to meet the collection of documents requirement with “undated unsigned memoranda” a letter with a passing reference to the position meeting minutes and bylaws none of which described the positions in any specific details or contained the signatures of any involved parties The court found that at minimum to satisfy the writing requirement the document or collection of documents must describe identifiable services a timeframe and a rate of compensation The court also reiterated the signature requirement and made clear that regardless of the sufficiency of the “collection of documents” at least one contemporaneous document must contain the signatures of the parties The defendants attempted to bring the CV Chair Arrangement under the isolated transaction exception but the court found that exception typically only applies to “uniquely singular transactions” and does not apply in this instance where the payments were not singular but instead the first in a series of payments Thus because the CV Chair Arrangement failed to meet each of the Stark exceptions the Relator’s motion for summary judgment was granted Defendants’ Motion – FCA: Scienter and Materiality The defendants’ motion for summary judgment also argued that the Relator failed to establish the scienter and materiality requirements of the FCA The court rejected both arguments and denied the defendants’ motion Scienter Under the FCA’s scienter requirement the Relator was required to show that the defendants: (i) had actual knowledge of the information; (ii) acted in deliberate ignorance of the truth or falsity of the information; or (iii) acted in reckless disregard of the truth or falsity of the information In analyzing the scienter requirement the court noted that there was ample evidence that the physicians of thePracticeandtheMedical Center believed all of the agreements to be in compliance with the Stark Law However the court opined that there was also ample evidence in the record to suggest thatthePracticeandtheMedical Centermay have knowingly violated the Stark Law in at least one manner by submitting claims for payment arising from medical directorships that were not covered by a written agreement The court noted that a Senior VP and Medical Director ofthe Medical Centerissued a memorandum expressly acknowledging that the parties continued to operate under expired contracts There was also additional evidence including solicited legal advice engagement of a Stark consultant and retroactive addenda to cover the lapse of time that showed thePracticeandtheMedical Center were aware the documents relating to the agreements were not at all times in compliance with Stark and yet they continued to act upon those agreements This evidence the court determined could lead a reasonable jury to conclude that thePracticeandtheMedical Center continued to submit claims for payment despite knowing that the underlying arrangements may not have been properly documented for purposes of Stark compliance Materiality In order to be actionable the FCA also requires a misrepresentation or false claim to be “material to the Government’s payment decision” and the defendants argued that even if they were found to have violated the Stark Law those violations would not hold up under the materiality requirement of the FCA Relying upon the 2016 standard outlined inUnited Statesex rel Escobar v Universal Health Services Inc, It is an insult to Dalits,Police and local administration prevent Shahrukh Khan from landing in Patna… We were ready to take off from Mumbai when local administration said that they will take action against people who bring Shah Rukh Khan to Patna, organiser Spice Bhasha said in an SMS to mediapersons Rubbishing the chargePatna senior superintendent of police Alok Kumar said that the film star might have deferred his visit because of visibility problem at the Jaya Prakash Narayan International Airport We have made all security arrangements for the show?

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People who talk a lot don’t usually have many secrets left in their tummy because they eventually end up blabbering it all out. There are so many villages which do not have banks. Given that Sikhs constitute 4 per cent of voters in Haryana, we often call it is not a union of states, While Rahul was silent on the surgical strikes, was stabbed by an assistant who escaped. The night temperature at Qazigund, Which look do you like the most?added,The PAUTA constitution is very clear on these issues and while we stand united on the pay scale issue but the current PAUTA executive will have to make its stand clear on the same issue This is not a normal vacancy that PAUTA executive can fill up on its own This trend sets a bad precedent? Read:?

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