Case Study: Regional Medical Center uncovers Stark Law and HIPAA violations with Consilio Riskcovery

Conceptual Analytics Assists with Department of Justice Request

Regional Medical Center worked with Consilio LLC after the government requested an investigation into potential Stark Law violations tied to free testing materials from a lab and suspected kickback-style referral arrangements. The hospital also needed to review the activity of a recently terminated employee, whose email and laptop data were available under the organization’s retention policy. Consilio used its Riskcovery platform and Conceptual Analytics to support the inquiry.

Consilio LLC ingested the data at the client site for HIPAA compliance, built a custom taxonomy from the Civil Investigative Demand and other sample documents, and used conceptual analysis to surface relevant communications. The review identified a key email outlining an agreement to send analyses to the lab in exchange for free testing materials, and also uncovered more than 3,000 emails sent to a personal account that included sensitive hospital and patient information. These findings enabled Regional Medical Center and counsel to expand the investigation, respond to the DOJ, and determine next steps for remediation.