Glenn P. Prives, Shareholder, Baker Donelson
ABA Enforcement Reality: Anti-Kickback, FCA & Growth Risk with Glenn Prives
Feb 26, 2026
Listen Compliance Audit · Fixed Scope
Know what is exposed before anyone asks.
A written assessment of your documentation and structure, with a prioritized fix list you can act on. Scoped before it starts. Finished when the assessment is delivered.
Already contacted by an auditor, payer, or regulator? Your first call is your counsel. This engagement is for before that call.
Written
An assessment you can act on
Prioritized
A fix list, in order
Cited
Every position to primary law
Before the call
Not after
What gets found late.
The record
The file describes a clinic you used to be
Documentation written once and never revisited does not match what the clinic does now. The gap is invisible until someone asks for the file.
The structure
Ownership nobody tested
Who owns the professional entity, and whether that fits the state, sits quietly for years. It stops sitting quietly when someone with money at stake asks.
The program
Nobody keeps it current
A risk analysis, a policy set, and training records only help when they are current and easy to find.
What you get.
01
A written assessment
Your documentation and your structure, read against the rules of the states you operate in. Every position cited to primary law, so you can act on it or hand it to your counsel.
02
A prioritized fix list
What to fix first, what can wait, and what needs counsel. In order, so the work can start right away.
03
The honest answer
If you are in good shape, you get that, plus what would have to change for you to stop being in good shape. If there is a problem, you get the problem and the options.
04
A fixed scope
Agreed before anything starts. No meter running. If the work is bigger than the audit, I say so before I begin, not halfway through.
Where it fits.
An audit tells you what is true at the time it is done. The research it draws on is published free. For the enforcement side, the podcast has a conversation with a Baker Donelson healthcare attorney on the Anti-Kickback Statute, the False Claims Act, and growth risk.
Find out what is actually exposed.
Thirty minutes. Describe the structure and the states you operate in. I will tell you whether an audit is the right first step.
Book a free 30 minute scoping callEngagements are business and compliance advisory, delivered alongside your counsel, who provides legal advice. Nothing here is legal advice. No engagement creates an attorney-client relationship.