Our Team


Richard P. Kusserow

RICHARD P. KUSSEROW
Chief Executive Officer

5911 Kingstowne Village Parkway, Suite 210
Alexandria, VA  22315

Email:
rkusserow@strategicm.com

Phone: (703) 683-9600
Fax:  (703) 836-5255

AREAS OF FOCUS

COMPLIANCE PROGRAM

  • Development
  •   Implementation
  •   Evaluation
  •   Education/Training
  •   Code/Policies

ANTI-KICKBACK STATUTE
STARK LAWS
INTERIM COMPLIANCE OFFICER
LITIGATOINS SUPPORT
INDEPENDENT EVALUATIONS/REVIEWS
HIPAA PRIVACY/SECURITY SERVICES
FORENSIC REVIEWS
INTERNAL INVESTIGATIONS/TRAINING
DUE DILIGENCE REVIEWS

INDUSTRY SPECIALITIES

HOSPITALS
ASC
PHYSICIAN PRACTICES
LONG TERM CARE
DISEASE MANAGEMENT
RENAL CARE/ESRD
CLINICAL/IMAGING LABS
PHARMA
EMERGENCY TRANSPORTATION

PROFESSIONAL EXPERIENCE

Mr. Kusserow established SM in 1992 and it has since specialized in developing, implementing and measuring effective compliance operations and programs. Under his leadership, SM provides a broad range of advisory services including organization assessments, financial/legal fact-finding, values and vulnerabilities assessments, program analyses, special studies/reports, policy development, and specialized education/training programs.  He has assisted organizations by providing interim and designated compliance officer services.  He provides specialized expertise on fraud and abuse, sanction, exclusion, and debarment processes, as well as regulatory issues arising from CMS. He possesses special and unique expertise involving fraud and abuse laws and regulations, such as the anti-kickback statute, qui tam actions, as well as environmental and product safety regulations, government contracting ethics. Under his personal leadership, SM has provided consulting assistance to over 800 companies, facilities, organizations and entities, large and small, for-profit and non-profit. 

PREVIOUS WORK
Mr. Kusserow served eleven years as the Inspector General (IG) for the Department of Health and Human Services (DHHS), where he was responsible for oversight over agencies with outlays of over $650 billion per year (38% of the annual outlays of the federal government).  He provided management direction and program leadership for a staff of 1500, which included budget staff, auditors, program analysts and criminal investigators, located in headquarters and 60 regional and branch offices nationwide.  Mr. Kusserow established policy and published fraud/abuse regulations; provided policy direction for the conduct of audits, investigations and program inspections and evaluations relating to all programs and operations of the DHHS. During his tenure as IG, Mr. Kusserow realized over $90 billion in fines, savings, restitution and recovery for the DHHS programs and the Treasury.  While IG, he testified before the United States Congress at over 100 hearings concerning the promotion of economy, efficiency and effectiveness in the Department's programs and operations. He maintained liaison with Federal prosecution and investigative offices in matters involving national law enforcement planning in program fraud and other forms of white-collar crime.  His responsibilities included fire, safety and security for 1,600 buildings nationwide, in which HHS occupied a major portion of the buildings.  Mr. Kusserow established DHHS policies for all aspects of security administration and guidelines for protection of classified documents and material pursuant to and in accordance with the provisions of Executive Order 12065, National Security Information, and safeguarding of non-classified sensitive information.  He was appointed by the President in 1989 as a National Advisory Commissioner on Law Enforcement.  He served as a member of the President’s Council on Integrity and Efficiency (1981-92); President’s Council on Management Improvement (1986 - 1992); Chief Financial Officer's Council (1991–2); and Attorney Generals White Collar Advisory Board.  He chaired the National Task Force on implementation of Chief Financial Officer's Act (1991-2).


Prior to becoming Inspector General, Mr. Kusserow served 11 years in the Federal Bureau of Investigation as a Special Agent and Supervisor.  He was coordinating Supervisor of the seven squads constituting the Organized Crime Program in Chicago. This included;  (1) "Rackets Squad", (2) "Joint FBI-DEA Task Force" the first joint program of this type; (3) "Undercover Surveillance/Technical Assistance" with 29 ground vehicles and two airplanes; (4)  "Organized White Collar Crime" focused on infiltration and corruption of legitimate business activities; (5) "Public Corruption" that countered criminal influence in government; (6) "Labor Racketeering"; and (7) "Top Hoodlum Program" designed to focus on organized crime leadership.  He was a recognized expert in program fraud and corruption investigations and lectured frequently at the FBI National Academy on these subjects.



EDUCATION/AFFILIATIONS/RECOGNITION

Bachelor of Arts, UCLA
Master of Arts, California State University at Los Angeles
Southern Methodist University Law School, Dallas, Texas
Executive Leadership Program, Kennedy School of Government, Harvard University
Evaluation and Effective Public Management, University of Southern California
John Marshall Law School, Chicago, Illinois
Management Team Development Workshop, Federal Executive Institute
Basic and Track Leadership Schools, United States Marine Corps

CURRENT/PAST AFFILIATIONS
American Health Lawyers Association
Society of Former FBI Agents (1981- )
Association of Federal Investigators (Twice Past National President)
Association of Government Accountants (Past National President)
Federal Law Enforcement Officers Association
National Welfare Fraud Association
Institute of Internal Auditors
Council for Excellence in Government
American Society for Industrial Security (ASIS)

RECOGNITION
Donald Scantlebury Award, Outstanding Leadership in Government Management, 1991
Office of Management and Budget, Significant Contribution in Implementation of the Single Audit Act
Meritorious Award, President's Council on Management Improvement (PCMI)
Presidential Citation
Special Recognition Award, Encouragement and Support of Audit Goals, Audit Agency
Outstanding Administration of Open Government Statutes, American Society of Access Professionals
Secretarys Bronze Medal, U.S. Department of Health and Human Services
Outstanding Service to the Nation, National Clearinghouse on Licensure, Enforcement and Regulation
Meritorious Service Rendered, National Association for State Information Systems
Leadership in Investigating White Collar Crime Seminar, Association of Federal Investigators


BOOKS
The Healthcare Compliance Professional’s Guide to Policies and Procedures, HCPro, 2008
49 Steps to Implement Sarbanes-Oxley Best Practices, AIS, 2006 (ISBN 1-933801-05-0)
Ultimate Hotline Manual: Tool Kit & Practical Guide for Establishing/Managing a Hotline Operation, 2005 (ISBN 0-9763344-0-2)
Sarbanes-Oxley: Best Practices for Private/Nonprofit Healthcare Entities, AIS, 2003 (ISBN 1-931467-53-6)
Corporate Compliance Education & Training Programs (A Manual and Guide), Opus Communications, 2001 (ISBN 1-57839-115-6)
Compliance Policies and Procedures (Assessment and Development). Opus Communications, 2000 (ISBN 1-57839-092-3)
Management Principles for Asset Protection, John Wiley & Sons, Inc., 1986, (ISBN 1-80938-1)
Principles of Targeting (Manual for Investigation of Fraud/Corruption), DOJ/FBI, 1974


PUBLICATIONS/PRESENTATIONS

Meet Richard Kusserow [HTML] [PDF]


Report on MEDICARE COMPLIANCE [HTML] [PDF]

Questions Raised About Necessity,Utility of Debarment Screening


Report on MEDICARE COMPLIANCE [HTML] [PDF]


Clarifying Sanction Screening:OIG LEIE and Entities versus GSA EPLS [HTML] [PDF]

Clarifying Sanction Screening:OIG LEIE and Entities versus GSA EPLS


Clarifying Sanction Screening: OIG LEIE and Entities versus GSA EPLS [HTML] [PDF]

Clarifying Sanction Screening: OIG LEIE and Entities versus GSA EPLS


Report on Medicare Compliance [HTML] [PDF]

Strategic Management is mentioned in the Report on Medicare Compliance on September, 29th, 2009. Anti-Fraud Provisions are expected to stay in the Senate's health reform plan.


New Compliance Officers Should Not Buy a Pig in a Poke [HTML] [PDF]

New Compliance Officers Should Not Buy a Pig in a Poke


Understanding the Complexities of Subsidy Payments for Hospitals [HTML] [PDF]

Understanding the Complexities of Subsidy Payments for Hospitals


Forgotten Issues in Physician Arrangements [HTML] [PDF]

Forgotten Issues in Physician Arrangements


The Latest on OIG Physician Arrangement Enforcement Actions [HTML] [PDF]

On February 27, Gregory Demske, assistant inspector general for legal affairs in the Office of Inspector General (OIG) of the Department of Health and Human Services testified before Congress on the subject of OIG enforcement relating to financial relationships involving physicians. The focus related to relationships between device manufacturers and physicians, although the implications are clear for hospitals and others with arrangements with physicians in a position to influence the referral of business.


Hospitals Cannot Form Intent to Violate the Law [HTML] [PDF]

Executives Might Pay More Attention to What They are Doing if They Knew They Could Be Held Liable. It is clear when you follow enforcement actions in the health care industry by the Department of Health and Human Services (HHS) Office of Inspector General (OIG) and Department of Justice (DOJ) that the number one enforcement priority relates to business relationships between referral sources and hospitals or other entities


Leasing Agreements between Hospitals and Physicians Draw Considerable Attention [HTML] [PDF]

Leasing arrangements between hospitals and physicians can be a very complex regulatory and enforcement areaThere are many areas of risks and vulnerabilities associated in light of the regulatory and enforcement environment, particularly as it relates to the federal anti-kickback statute and Stark laws


Understanding the Importance of Reviewing Agreements with Physicians JHCC, November 2007


Hospital-Based Physicians Under the Kickback Statute: Not Forgotten JHCC, September 2007


Enterprise Risk Management: The Next Evolutionary Step in Compliance JHCC, July 2007


Should Your Hotline Be Out-Sourced, or Should It Be Operated In-House? JHCC, May 2007


Compliance Hotlines Establish Better Connection to the Workforce JHCC, March 2007.


How Do You Know Which Hot Line Vendor is Right for Your Organization? JHCC, January 2007.


Do You Ever Find It Challenging to Operate an Effective Hot Line? JHCC, November 2006.


Stark Law: Using its History to Craft its Future JHCC, November 2006.


Exit Interviews: Another Important Compliance Communication Channel JHCC, September 2006.


Deficit Reduction Act Mandates Education on Fraud and Whistleblowers JHCC, July 2006.


Adapting Sarbanes-Oxley Act; Best Practices for Health Care Organizations JHCC, January 2006


A Look Back at the Origin of the Stark Self-Referral Law JHCC, November 2005


SOX Invades Nonprofit World; Mesh SOX Best Practices & OIG Compliance Medicare Compliance, September 2005.


Sarbanes Oxley Act Hotlines: The New Best Practice Standard for Health Care Entities? JHCC, May 2005.


Business Associate Agreements, PHTS Client CEI E-zine September 2002.


HIPAA Guidance, PHTS Client CEO Update July 2002.


Exit Interviews Provide Many Advantages, PHTS The Credentialing Factor May 2002.


Compliance Effectiveness Outcome vs. Output, Journal of Health Care Compliance JHCC, September 2000.


Screening Tool Can Detect Sanctioned Providers, PHTS View Point June 2000.


Tips on Hotline Anonymity, PHTS Innerviews May 2000


CIA Independent Review Requirements The American Compliance Institute, Compliance Update, March 2000.


Regular Column in the Journal of Health Care Compliance 2000


What You Can Learn From Corporate Integrity Agreements (with Andrew H. Joseph), JHCC, November 1999


Managing Decisions for a New IG: Lessons Learned The Journal of Public Inquiry, Fall/Winter 1998.


Inspector General: 20 Years Later Issues Then and Now, Government Accountants Journal, Fall 1998.


Medicare & Medicaid Anti-Kickback Statute and Safe Harbor Regulations What Next? Case Western Reserve University, Journal of Law-Medicine, V.2, Spring 1992.


What You Can Learn From Corporate Integrity Agreements Journal of Health Care Compliance, December 1990.


Today' s Analysis; Tomorrow' s Reality The Government Accountants Journal, Winter 1989/1990.


Monitoring Research Programs: The HHS Experience Assistance Management Journal, winter 1989.


The Social Security Wild Card The GAO Journal, Winter 1988/89.


The Investigator-Prosecutor Team The Investigator's Journal, 1989.


Sanctions and Quality of Care Quality Assurance and Utilization Review, November 1988.


Inspector General Responds to Criticisms Nephrology News and Issues, February 1988.


Diagnostic Coding Under the Prospective Payment System New England Journal of Medicine, February 11, 1988


Audited Financial Statements: Social Security Administration Government Accountants Journal, 1988


Computer-Related Fraud and Abuse Information Management Review, Spring 1988.


The State Boards: Perceptions of the OIG, Federation Bulletin, November 1987


Overview of State Medical Discipline Journal of the American Medical Association (JAMA), February 13, 1987.


Government Closely Eyes Labs' Medicare Abuses Journal of Am. Assn. Clinical Chemistry, June 1986


An Inside Look at Federal Computer Crime Security Management Journal, May 1986.


Investigating 'Kickback' Schemes The Investigator's Journal, Fall 1986.


Protecting the Public Caring Magazine, June 1985.


Computer Matching The Council of State Governments, April 1985.


False Identification - A Multimillion Dollar Problem The Investigator's Journal, Summer 1985


Point Counter Point AEDS Monitor, September/October 1984.


Computer Related Fraud and Abuse in Government Agencies Computer Security Newsletter, July 1984.


Government Needs Computer Matching to Root Out Waste & Fraud Communications, June 1984.


Policing Medicare and Medicaid Business and Health, May 1984.


Monitoring of Medicare Abuses HMQ/Health Management Quarterly, Winter 1984-85


Program Inspections The Government Accountants Journal, Spring 1984.


Initiatives for Improving Accountability NACUBO Business Officer, September 1983.


Civil Monetary Penalties Law of 1981 Notre Dame Law Review, June 1983.


Fighting Fraud, Waste, and Abuse The Bureaucrat, Fall 1983.


The IG Reports Newsletter of The National Welfare Fraud Association Fraud Forum, 1983.


Stopping Identification Fraud The Hartford Courant, May 28, 1982.


End Stage Renal Disease program Contemporary Dialysis, April 1982.


Medicare Fraud and Abuse: Understanding the Law National Health Lawyers Association


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