Protect compliance practices

A pending federal lawsuit against Tenet Healthcare Corporation's former general counsel and compliance officer Christi R. Sulzbach offers a worst-case cautionary tale for those charged with certifying a healthcare system's integrity.

The government, in its September 2007 lawsuit, alleges that Sulzbach was aware a Tenet-owned hospital in Florida illegally billed Medicare for referrals from doctors whose contracts violated the Stark Law. It further alleges that, despite this knowledge, Sulzbach signed several declarations in the late 1990s indicating that Tenet was in compliance with all federal program legal requirements:

... Sulzbach's false declarations allowed Tenet to bill Medicare for millions of dollars in claims that it was not legally entitled to receive under the Stark Statute ... Her false declarations also obstructed the government's discovery and recoupment of millions of dollars of improper payments that Tenet had already received.