Distance Learning Center

Educating and Connecting the Health Law Community.

New CMS Program Integrity Final Rule Is Here—Guideposts for Operationalizing the New Disclosure Requirements

Recorded On: 11/06/2019

  • Registration Closed

Time: 2:00-3:30 PM Eastern (90 minutes)
Session Format: Live Webinar
CLE Credit Available:  Yes

On September 5, 2019, CMS released a final rule with comment period called "Medicare, Medicaid, and Children's Health Insurance Programs; Program Integrity Enhancements to the Provider Enrollment Process." Finalizing a proposed rule from 2016, CMS has imposed new enrollment disclosure requirements and created new avenues for denying or revoking enrollments across the range of providers and suppliers that participate in Medicare, Medicaid, or CHIP. Beginning November 4, 2019, providers and suppliers will be required to disclose certain current or past “affiliations” with other providers and suppliers if those affiliated providers and suppliers have been subject to a “disclosable event.” One key to understanding the impact of this final rule is understanding the broad scope of both “affiliation” and “disclosable events.” Hospitals, SNFs, physicians, and other providers and suppliers will need to keep track of a new range of conduct among a new range of relationships. Failure to track and disclose these affiliations will be at one’s peril, as CMS has authority to deny or revoke an enrollment if it determines that an affiliation presents “an undue risk of fraud, waste, or abuse” or if the provider or supplier failed to disclose the affiliation. The goals of this webinar will be to describe key concepts in the final rule and give those representing providers and suppliers guideposts for how to operationalize the new affiliation tracking that CMS has imposed. The webinar will focus on practical examples and takeaways.

Level of Difficulty: Intermediate

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Content Lead:

  • Regulation, Accreditation, and Payment Practice Group


Ross Sallade


Polsinelli PC
Raleigh, NC

​Colin P. McCarthy, JD (Moderator)


McGuireWoods LLP
Richmond, VA

Jeanne L. Vance, Esq.

Shareholder/Corporate Secretary

Salem & Green, A Professional Corporation
Sacramento, CA

The “Listen with a Colleague" option allows multiple registrants from the same organization and location to participate in the webinar at a discounted rate. It may ONLY be used if at least one person from your organization and location has registered at the regular/full webinar registration rate. Please note that those who register under the reduced “Listen with a Colleague" rate must access the webinar from the same location and computer as the full-priced registrant they are registered under.

The “Listen with a Colleague" option is continuing legal education (CLE) credit-eligible. In order to obtain a certificate of completion for submission to a state CLE accrediting body, those registered under this option must obtain the attendance verification code—which will be displayed at a random time during the webinar—and enter that code under “Verification Code for Live Webinar" section of the webinar description webpage. Please note that each registrant must submit a complete evaluation from their individual accounts to obtain a certificate of completion.

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