“If a provider does something [in its Medicare billing] once, it’s an incident, twice is an occurrence, three times is a trend, four times is a pattern and five times is an agenda.”
— Arthur Di Dio, M.D., a trial attorney in the Department of Justice’s commercial litigation branch, speaking at the recent Fraud and Compliance Forum co-sponsored by the Health Care Compliance Assn. and American Health Lawyers Assn.
The same thing could be said about HIPAA compliance. An organization's agenda could be just "thumbing its nose at HIPAA 2.0" and that is almost guaranteed to get you a willful neglect fine of up to $1.5M or more.
