Alerts/Presentations

This section includes client alerts and educational presentations concerning PODs.

• OIG Finds Physician-Owned Medical Device Innovator Not a Suspect “POD”, Ropes & Gray Healthcare Alert, April 2022
• Proposed Rule on CY 2022 Physician Fee Schedule Addresses Telehealth (Especially Mental Health), Drug Pricing and Reimbursement, Provider Enrollment, Vaccines, and Physician-Owned Distributor Transparency, Ropes & Gray Healthcare Alert, August 2021
• Medicare Payment Advisory Commission (MedPAC) included a section on physician-owned distributors of medical devices (PODs).   
• Staff of the Medicare Payment Advisory Commission (MedPAC) gave a presentation to the commission recommending that dealings with physician-owned distributors of implantable medical devices (PODs) be prohibited under the Stark law.
• "MedPAC Takes Anti-POD Stance in Report to Congress, Echoing an Increasingly Uniform Consensus," Tom Bulleit and Peter Holman, RG Healthcare Alert, June 2017
• "Senate report discourages dealings with physicianowned distributorships," Tom Bulleit and Peter Holman, Compliance Today, March 2017
• "POD Update: Physician Investor of Physician-Owned Distributor Sentenced to Nearly 20 Years in Prison," Tom Bulleit, RG Healthcare Alert, January 2017
• "Senate Finance Report Puts another Nail in the POD Coffin," Tom Bulleit and Peter Holman, Ropes & Gray Healthcare Alert, May 2016
• "Physician-Owned Distributorships Under Scrutiny at Senate Finance Committee Hearing," Tom Bulleit and Lisa Guo, Ropes & Gray Healthcare Alert, December 2015
• "Son of POD: New FCA Challenge to Latest Variation on Physician-Owned Distribution," Tom Bulleit, Ropes & Gray Healthcare Alert, March 2015
• "U.S. Department of Justice Files False Claims Action Against 3 PODs and Physician Investors for Physician and Hospital Claims," Tom Bulleit and Peter Holman, Ropes & Gray Healthcare Alert, September 2014
• "Physician Owned Distributorship Concerns Continue to Make News," Tom Bulleit and Peter Holman, Ropes & Gray Healthcare Alert, June 2014
• "Justice Department Filing Makes Clear That Current False Claims Act Investigation Focuses on POD, Associated Hospital and Individual Doctor," Tom Bulleit and Peter Holman, Ropes & Gray Healthcare Alert, March 2014
• "OIG’s Bad News for PODs: Whither (or Wither) the Physician-Owned Supply Chain?," Inside HSCA Guest Blog, Tom Bulleit, February 2014
• "Court Dismisses POD Lawsuit Against OIG," Tom Bulleit and Peter Holman, RG Healthcare Alert, February 2014
• "Physician-owned entity fraud alert: Hospital compliance officers take note," Tom Bulleit, Sara Kraner, Eliza Andonova, Natalie Morris, Compliance Today (subscription required), December 2013
• "Physician-Owned Distributors (PODS): A Bad Gamble for Hospitals," Informational Package May 2013
• "Implications of OIG’s Special Fraud Alert on current PODs and their customers and suppliers: No more free lunch," Tom Bulleit et al., HL HealthLaw Alert, April 2013
• "OIG determines that PODs are “inherently suspect” under the anti-kickback law," Tom Bulleit et al., HL HealthLaw Alert, March 2013
• "Past AANS President questions whether PODs violate Medical Ethics," James Bean, MD, FAANS, AANS Neurosurgeon, November 2012
• "Physician-Owned Distributors: To Be or Not To Be?," Tom Bulleit, Charles Oppenheim, Kim Brandt, American Health Lawyer Association Webinar, September 2012
• "Physician-Owned Distributorships (PODS): Quick Profit or Legal Hazard?" Presentation by Bill Kolter, Biomet Inc., August 2012
• "Update on California A.B. 378: Still Prohibiting PODs for California Workers' Compensation; Some Important Exceptions," Tom Bulleit et al., HL HealthLaw Alert, February 2012
• "New California law prohibits medical device physician owned companies in workers compensation program," Tom Bulleit et al., HL HealthLaw Alert, January 2012
• "OIG Releases Advisory Opinion Demonstrating Continued Concern with Physician-Owned Companies," Tom Bulleit et al., HL HealthLaw Alert, October 2011 
• "Senate asks OIG to probe physician-owned distributors," Tom Bulleit et al., HL HealthLaw Alert,  June 2011 
• "OIG Settles Kickback Case with Physician-Owned Company for Leveraging Patient Referrals to Obtain Contract Business from Hospitals," Tom Bulleit et al., HL HealthLaw Alert, July 2010
• "Physician-Owned Intermediaries in the Medical Device Industry: The Case for Government Scrutiny Under the Fraud and Abuse Laws," Tom Bulleit, Steve Immelt, Ron Wisor, Whitepaper, February 2009 
• "Physician-Owned "Distributors" of Spinal Implants: The Impropriety of Physicians as Commissioned Sales Representatives," Tom Bulleit, John Murphy, Whitepaper, November 2009