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Department of Justice and other government entities regarding various Medicare and Medicaid issues.
−Removed: In addition, we are subject to other claims and lawsuits arising in the ordinary course of our business including lawsuits and claims related to billing and collection practices at our hospitals.
+Added: In addition, we are subject to various other legal, regulatory and governmental proceedings incidental to our business, including lawsuits and claims related to billing and collection practices at our hospitals.
Based on current knowledge, management does not believe that loss contingencies arising from pending legal, regulatory and governmental matters, including the matters described herein, will have a material adverse effect on the consolidated financial position or liquidity of the Company.
However, in light of the inherent uncertainties involved in pending legal, regulatory and governmental matters, some of which are beyond our control, and the very large or indeterminate damages sought in some of these matters, an adverse outcome in one or more of these matters could be material to our results of operations or cash flows for any particular reporting period.
−Removed: Settlements of suits involving Medicare and Medicaid issues routinely require both monetary payments as well as corporate integrity agreements.
+Added: Settlements of suits involving Medicare and Medicaid issues routinely require monetary payments as well as corporate integrity agreements.
Additionally, qui tam or “whistleblower” actions initiated under the federal False Claims Act, or FCA, may be pending but placed under seal by the court to comply with the FCA’s requirements for filing such suits.
−Removed: In September 2014, the Criminal Division of the Department of Justice announced that all qui tam cases will be shared with their division to determine if a parallel criminal investigation should be opened.
−Removed: The Criminal Division has also frequently stated an intention to pursue corporations in criminal prosecutions, including in its most recent Memorandum dated September 15, 2022.
−Removed: From time to time, we detect issues of non-compliance with federal healthcare laws pertaining to claims submission and reimbursement practices and/or financial relationships with physicians.
+Added: The Department of Justice has also stated an intention to pursue corporations in criminal proceedings when appropriate.
+Added: Qui tam investigations and related government actions may also give rise to such criminal proceedings.
+Added: Moreover, from time to time, we detect issues of non-compliance with federal healthcare laws pertaining to claims submission and reimbursement practices and/or financial relationships with physicians.
We avail ourselves of various mechanisms to address potential overpayments arising out of these issues, including repayment of claims, rebilling of claims, and participation in voluntary disclosure protocols offered by CMS and the HHS Office of Inspector General.
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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.