Compare And Contrast Greber And Bay State

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1) In both Greber and Bay State, each case provides an analysis for potential Anti-Kickback violations, however how the court determined if the violation occurred were slightly different. In United States v. Greber, the U.S. Court of Appeals for the Third Circuit established the “one purpose” test which states, “if one purpose of the payment was to induce future referrals, the Medicare statute has been violated.” U.S. v. Greber, 760 F.2d 68, 69 (3rd Cir. 1985), cert. denied, 474 U.S. 988 (1985). The one purpose test has later been adopted by the Fifth, Ninth, and Tenth Circuits. In U.S. v. Bay State Ambulance and Hospital Rental, Inc., the First Circuit instructed the jury to apply the primary purpose test which states that the primary purpose must be improper in order to obtain a conviction under the Anti-Kickback Statute. See U.S. v. Bay State Ambulance and Hospital Rental, Inc., 874 F.2d 20, 32 (1st Cir. 1989). 2) …show more content…

Intent can be misinterpreted or the violation may be unintentional but in both Greber and Bay State, the intent to violate was clearly established. In Greber, the defendant interpreted the results and claimed that the physicians were paid for the interpretation of the results. This is a blatant act of deceit. In Bay State, the defendant Felci intentionally concealed the fact that he had a relationship with Bay State and conducted inappropriate acts including voting for the Bay State contract while serving of the board without disclosing the relationship, providing false information to the Board regarding the contract and receiving gifts and moneys during the

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