Fighting Back Against Prosecutorial Abuse‪.‬

It will not be necessary for my brief note here to reiterate at length the dire perils confronting physicians under Medicaid and Medicare, which are enacted into law. Physicians must use the ever-changing AMA promoted/ copyrighted current procedural terminology (CPT) coding system, and are subject to thousands of rules and regulations contained within Title XVIII (Medicare) and Title XIX (Medicaid) of the Social Security Act. Any presumed violation of these rules can be prosecuted by the Office of Inspector General (OIG), Centers for Medicare and Medicaid Services (CMS), Federal Bureau of Investigation (FBI), Department of Justice (DOJ), state attorneys general (AGs) via state Medicaid Fraud Control Units (MFCUs) and other entities, or any county attorney--all upon ill-defined "information and belief." Prosecutions can also come from the Program Integrity Unit (PIU), Healthcare Fraud Prevention and Enforcement Team (HEAT), Comprehensive Error Rate Testing program (CERT), Superior Utilization Review System (SURS), Recovery Audit Contractors (RACs), Medicare Administrative Contractors (MACs), Zone Program Integrity Contractors (ZPICs), and whistleblowers, who are free-lance bounty hunters ofquestionable qualifications.