James A. Cannatti III

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James A. Cannatti III* practices at the intersection of today's most pertinent health care issues, including digital health, health IT policy, and fraud and abuse, including Anti-Kickback Statute/Stark Law matters. With more than 10 years of experience in the US Department of Health & Human Services’ (HHS) Office of Inspector General (OIG), most recently as Senior Counselor for Health Information Technology, James is well-attuned to the regulatory issues impacting the rapidly evolving digital health landscape. Read James A. Cannatti III's full bio.  *Not admitted to practice in the District of Columbia; admitted only in Ohio. Supervised by principals of the Firm who are members of the District of Columbia Bar.

How Not to Lose $1 Million: Preparing for OIG’s Information Blocking Enforcement


By and on Oct 4, 2023
Posted In Consumer Protection, Data Privacy, Data Transfers/Safe Harbor/Privacy Shield, Telehealth

OIG’s long-awaited final rule on investigating and imposing penalties for information blocking dropped in July 2023 and is effective as of Sept. 1, 2023 – almost three years after OIG released its proposed rule (April 2020) and two years after the start of information blocking compliance on April 5, 2021. The final rule codifies OIG’s...

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HHS OIG Develops Toolkit to Analyze Telehealth Claims to Assess Program Integrity Risks


By , , , and on May 12, 2023
Posted In Telehealth

On April 20, 2023, the United States Department of Health and Human Services Office of the Inspector General (HHS OIG) released a new toolkit designed to help analyze telehealth claims to assess federal healthcare program integrity risks. The toolkit is OIG’s latest action in its continued focus on telehealth services that OIG considers to be high risk....

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National Telehealth Takedown Highlights Opportunity for Providers to Enhance Compliance Efforts


By , , , , and on Oct 19, 2020
Posted In Telehealth

The US Department of Justice and the US Department of Health and Human Services Office of Inspector General recently announced a significant healthcare fraud takedown involving $4.5 billion in allegedly false and fraudulent claims involving telehealth. The allegations involved telehealth executives paying healthcare providers to order unnecessary items and services, as well as payments from...

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Can We Expect to See ONC’s Final Rule on Information Blocking Soon?


By , , and on Oct 30, 2019
Posted In Data Privacy, General Interest

A recent update to the Office of Management and Budget (OMB) website suggests that the answer is “yes”—though that depends on how one defines “soon.” According to its website, OMB received the Office of the National Coordinator for Health Information Technology’s (ONC’s) final rule, entitled 21st Century Cures Act: Interoperability, Information Blocking, and the ONC...

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Health Care Enforcement Roundup: Increased FCA Enforcement Against EHR Companies


By , and on May 9, 2019
Posted In Uncategorized

The federal government has offered substantial incentives to providers to adopt and use certified electronic health record (EHR) technology. As of October 2018, the federal government had paid over $38 billion in EHR incentive payments through the Promoting Interoperability Program (formerly, the Meaningful Use Program). Other federal health care program policies also encourage use of...

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DOJ’s Enforcement Activity Against Individuals: Acute Focus on Telemedicine


By , and on May 6, 2019
Posted In Telehealth

DOJ’s focus on individual accountability is particularly important with respect to telemedicine. Telemedicine is a burgeoning field, with a projected market increase of 18 percent annually over the next six years, reaching $103 billion in 2024. In light of this recent surge in profitability, DOJ has begun paying extra attention to telemedicine, with at least...

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ONC Sends Information Blocking Proposed Rule to OMB


By on Sep 19, 2018
Posted In General Interest

The Office of the National Coordinator for Health Information Technology (ONC) is one step closer to issuing its long-awaited proposed rule to implement various provisions of the 21st Century Cures Act, including proposed regulations distinguishing between prohibited health information blocking among health care providers and health information technology vendors and other permissible restrictions on access...

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