License revocations or termination of participation in federal programs is the
administrative death penalty. Agencies use these as a last resort. In most
cases, the agency will enter an administrative order specifying what must be
done to eliminate the violation. This may be to clean up the refrigerator in the
hospital kitchen, to build fire escapes, or to stop billing for work that the health
care practitioner is not personally supervising. Many agencies may also assess
fines or other civil penalties, such as reimbursement for improper payments.
These penalties can run to tens of millions of dollars if they involve systematic
improper billing to the federal government. A hospital would have little choice
but to pay the penalty because termination of its participation in federal
programs will put it out of business.