Distance Learning

New CMS Program Integrity Final Rule is Here - Guideposts for Operationalizing the New Disclosure Requirements - On Demand Recording

Recorded On: 11/06/2019

Time: 90 minutes
Session Format: On Demand Recording
CLE Credit Available:  No

In most states, AHLA webinars meet the requirements for continuing legal education and attorneys may self-apply for CLE credit. AHLA’s live distance learning webinars are pre-approved for CLE credit in the following states: Alabama, Illinois, Nebraska, New Jersey, Pennsylvania, South Carolina, Texas, Virginia and West Virginia. Please refer to Distance Learning CLE reporting procedure for more information.

For on-demand webinar recordings, streaming access is available for 12-months from the date of the live webinar.  After 12-months, on-demand webinar recordings are available through the AHLA Health Law Archive.

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

  • AHLA Member: $99
  • Non-AHLA Member: $149

Content Lead:

  • Accreditation, Certification, and Enrollment Affinity Group


  • 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