Do the right thing at the right time for the patient. It’s based on indications which is what I’ve stated. If the indications are appropriate one need not be concerned. I’ve given no cliche such as you stated.
"If you have done nothing wrong, then you have nothing to worry about" is such a cliche.
Even if you prevail by proving that you are doing the right thing, the economic impact of the investigation itself can be devastating. It could literally cost you hundreds of thousands of dollars to prove your innocence.
The "crime" is also one of strict liability. Intentions are irrelevant.
The OIG report is based on claims data that is well-known to be inaccurate.
It exaggerates the use of tibial intervention for claudication because whatever pathology was being treated was incorrectly coded as such.
In addition, there is also the question of atherectomy. The subject is a matter of scientific debate. It is not appropriate to settle these questions as a law enforcement exercise.
We all know that PAD is rampant and the majority of limb amputations related to PAD occur without even an angiogram being done. The OIG report is going to have a chilling effect on the inadequate numbers of interventions that are being done.
It would be awesome to think that the DOJ/OIG would bring a scalpel to this issue. But they don't have any instruments that fine. There is a significant probability that someone is going to get caught up in this process that doesn't deserve to be.