You are outside counsel to the Marcus Welby Healthcare Corporation, which among its other operations owns a durable medical equipment (DME) subsidiary, which sells equipment for home use such as crutches, wheelchairs, and oxygen concentrators. You learn that the subsidiary has had certain business practices about which you have some question under the Medicare and Medicaid Anti-Fraud and Abuse provisions:
- Salesmen regularly offer home health agency employees a "premium" whenever their clients order DME from the subsidiary.
- The subsidiary offers "rebates" to patients who use its equipment.
- The subsidiary pays hospital and home health agency personnel for assisting its patients in learning how to use its products.
- Some arterial blood gas test results may have been "massaged a bit" by the DME in order to facilitate Medicare payment for oxygen concentrators.
What advice would you give?