Small Smiles Dental Centers: Reporting of Adverse Events

The Corporate Integrity Agreement requires Church Street Health Management to self report what is referred to as “Reportable Events” that take place at their Small Smiles Dental Centers across the US. 
What is a “Reportable Event” as seen by Small Smiles Dental Clinics:

1. Billing that would generate more than $4000 in overbilling – Keep erroneous or any fraudulent bilking billing under that mark and they are good to go.  Is that per child?  Could also be defined as a matter that a reasonable person would consider a probable violation of civil, criminal or administrative law applicable to federal health care programs . Or a matter that a reasonable person would consider likely to render CSHM insolvent.
2. Quality of Care Reportable Event– Adverse Events (AE).  These are a bit more difficult to define, since they are in the eyes of the beholder.  Basically anything that involves a violation of the obligation to provide items or services of a quality that meets professionally recognized standards of care.  In my opinion, that would include unlocking the door to any of the now, 72 clinics. The great White Paper King, Steven Adair is making those decisions.  Not a good choice in my opinion.  What is his pay based on?   Does he get a “production” bonus too? It may be that these are only events reported that cause a Corrective Action Plan (CAP) to be initiated.  What is a CAP, you ask?  Well, it could be a simple letter of instruction to the treating dentist/staff member,  a DVD for them to watch, or further training that they decide will do.
3. Event that would cause law enforcement to be notified–  I wonder if that means local law enforcement or the Feds?  You know what I mean, a dentist punches a patient in the face or staff forges names and signatures on documents?  Could also be defined as a matter that a reasonable person would consider a probable violation of civil, criminal or administrative law applicable to federal health care programs .  Again I feel that unlocking the doors on these houses of horrors should be criminal since I promise something illegal happens in each one of them everyday.

If CSHM doesn’t correct the billing within 30 days or