Legal Resources:

Letters, Testimony, Position Papers

Letter
To CMS re: CMS' proposed exception to self-referral prohibition, August 27, 2008

Letter
To the OIG re: hospital billings/collection, Nov. 14, 2003

Testimony
FTC/DOJ Health Care Hearings "Perspectives on Competition Policy and the Health Care Marketplace: Single Specialty Hospitals," March 27, 2003

Testimony
FTC/DOJ Health Care Hearings "Perspectives on Competition Policy and the Health Care Marketplace," February 27, 2003

Letter
To the OIG re: credentialing practices under the anti-kickback statute, February 5, 2003

Letter
To the OIG re: the compliance program guidance for hospitals, August 19, 2002

AHA Position
The Wrongful Denial of Medicare Losses on Sale Involving Mergers and Consolidations of Non-profit Hospitals by the Department of Health and Human Services, April 2002

AHA White Paper
AHA Position on HHS' Denial of Medicare Losses in Non-Profit M&As, September 6, 2001

Special Report
To the American Hospital Association, Pneumonia Coding Project: Investigations, Defenses And Affirmative Compliance Measures, February 2001

Letter
To the OIG re: proposed safe harbor for ambulance restocking, July 21, 2000

Letter
To OIG re: Medicare and State Health Care Programs: Fraud and Abuse; Issuance of Advisory Opinion by OIG (62 Fed. Reg. 7350 et seq., February 19, 1997), April 21, 1997

Letter
To HHS Inspector General re: Solicitation of New Safe Harbors and Modifications to Existing Safe Harbors, March 3, 1997

Letter
To the IRS re: excise taxes and charitable organizations, December 12, 1996

Letter
To NAIC re: NAIC White Paper, "The Regulation of Risk-Bearing Entities," November 1, 1996

Testimony
Statement of the AHA submitted to the FTC [antitrust], December 11, 1995

Special Report
"Regulation of Health Plan Companies and Provider Sponsored Networks: Practical and Public Policy Considerations", April 25, 1995