In early November, the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) released its General Compliance Program Guidance (the Guidance). This was HHS OIG’s first update since 2008....more
In October 2023, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) published Advisory Opinion 23-07 and approved a plan by a multi-specialty physician practice to pay its employed...more
The HHS Office of Inspector General issued an 'unfavorable' advisory opinion in August with respect to a proposed joint venture relating to interoperative neuro monitoring. Parties considering joint ventures and those in...more
On November 8, 2021, the United States Department of Health and Human Services (HHS) Office of Inspector General (OIG) released an updated Self-Disclosure Protocol (SDP) (here). The revision of the SDP is an important...more
In a recent advisory opinion, the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“HHS”) concluded that an investment by a health system, a management company, and surgeons in an...more
On November 16, 2020, the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“HHS”), issued a Special Fraud Alert highlighting the Anti-Kickback Statute (“AKS”) risks for pharmaceutical...more
The Saul Ewing Arnstein & Lehr, LLP Health Care Practice includes attorneys that handle regulatory, compliance, transactional and litigation needs for clients across the entire health care delivery system, including: ...more
On October 9, 2019, the Centers for Medicare and Medicaid Services (CMS) and Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS), each issued a proposed rule to amend respectively the...more
There continues to be significant media attention on health care privacy and data breaches, the opioid crisis, Medicaid funding and expansion efforts, telemedicine, and mergers and acquisitions affecting the health care...more
In what may be one of the final federal health care revisions implemented during the Obama Administration, on December 7, 2016 the U.S. Department of Health and Human Services (“HHS”), Office of Inspector General (“OIG”),...more
On November 10, 2016, the U.S. Department of Health and Human Services, Office of Inspector General (“OIG”) posted its work plan (the “Work Plan”) for fiscal year 2017. The OIG publishes its Work Plan on an annual basis. The...more
On August 18, 2016, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced plans to expand its investigations of reported breaches of the Health Insurance Portability and...more
In November 2015, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) released its investigative plans for fiscal year 2016 (the OIG Work Plan). The OIG Work Plan highlights more...more
On Thursday, October 29, 2015, the Centers for Medicare & Medicaid Services (“CMS”) and the Office of Inspector General (“OIG”) jointly issued a rule (the “Final Rule”) to finalize five (5) waivers of certain fraud and abuse...more
11/5/2015
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Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
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Healthcare Fraud ,
Interim Rule ,
Kickbacks ,
Medicaid ,
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Medicare Shared Savings Program ,
OIG ,
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Shared Savings Program ,
Stark Law
On September 29, 2015, the Office of Inspector General (OIG) released two reports that reviewed the Office of Civil Rights’ (OCR) enforcement of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The...more
On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) published a one-page fraud alert entitled, "Physician Compensation Arrangements May Result in Significant Liability." This is the...more
On October 17, 2014, the Centers for Medicare and Medicaid Services (CMS) and the U.S. Department of Health and Human Services, Office of Inspector General (OIG) published in the Federal Register (79 FR 62356 et seq) a notice...more
In the December 27, 2013 edition of the Federal Register, the Office of Inspector General (“OIG”) and Centers for Medicare and Medicaid Services (“CMS”), both within the U.S. Department of Health and Human Services (“HHS”),...more
The federal government invests significant resources in combating health care fraud and abuse. The U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) recently released its Strategic Plan...more
In June 2013, the Department of Health and Human Services, Office of Investigator General (OIG) published a review of its audit of an outpatient therapy services provider. The OIG concluded that the outpatient therapy...more
Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity.
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The OIG recently posted an Advisory Opinion which concluded that a hospital's proposal to provide free access to an electronic interface between the hospital and area physicians for laboratory and diagnostic services was not...more
On October 30, 2012, the Office of Inspector General, Department of Health and Human Services ("OIG") posted an Advisory Opinion stating it would not challenge an arrangement in which a non-profit hospital pays per diem...more