I think that Citron made a critical error in their report that hurts one of their main arguments. They say...
"According to records obtained from the State of Florida Agency for Health Care Administration (AHCA) the largest medical center submitting for reimbursements for procedures using CPT codes for the Arthrocare device is none other than Palm Beach Lakes Surgical Center and its two partners Dr. Kugler and Dr. Gomez. The second largest biller in the whole state of Florida (the majority of ARTC spine business) is Dr Dennis Zaslow. Mr. Zaslow has twice been charged with insurance fraud."
The error is that their is no CPT code for just the ARTC device. There is a code but it for PDD and other similar operations such as the one using the Stryker Decompressor. Here is a link to a BCBS coverage position. Note that at the end there is one CPT code for all of these procedures. There is not a specific code for only ARTC.
Additonally, if you go the the message on this board titled "discocare" you will understand why the majority of the ARTC spine business does not go through this one surgical center. It's not even possible. They would have to do about 90 procedures per day at the surgical center. Therefore, a majority of the spine biz does not go through this surgical center.
I think I've done a good job in illustrating how Citron is incorrect on this part of their report, which is critical to their thesis. So if this is wrong, then why should we believe anything in their report???