Program design
Show me this working in the last ninety days
Most programs can name the OIG's seven elements. Far fewer can show them operating. Here's how to tell the difference during a gap analysis.
Brandon Goulter · 6 min read
Privacy
HIPAA is the floor. In California, CMIA is the ceiling.
Why provider networks that build only to the federal standard still carry real exposure under California's stricter privacy regime, and where the gaps usually hide.
Brandon Goulter · 7 min read
AI governance
You don't need an AI governance framework. You need your compliance program.
Ambient scribes and AI coding tools are arriving faster than the contracts covering them. A mapping of each OIG element onto AI risk, and the five places the fit is genuinely imperfect.
Brandon Goulter · 8 min read
Risk defense
Reading a physician arrangement before Stark reads it for you
A field guide to the transaction reviews that keep fair-market-value and commercial-reasonableness questions from becoming enforcement questions.
Brandon Goulter · 8 min read