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CMS Publishes Final Rule on Civil Monetary Penalties for Section 111 Reporting

The Centers for Medicare and Medicaid Services (CMS) published the final rule outlining how civil monetary penalties will be calculated and imposed when Responsible Reporting Entities (RRE) fail to meet their Medicare...more

DC Circuit Revives Medicare Advantage Overpayment Rule

On August 13, the D.C. Circuit revived the CMS 2014 Medicare Advantage Overpayment Rule in deciding UnitedHealthcare Ins. Co. v. Becerra, a ruling that could have broad implications for Medicare Advantage (MA) insurers. See...more

OIG Advisory Opinion Has Key Takeaways for Programs Designed to Assist Needy Patients

Can a pharmaceutical manufacturer provide free items or services to financially needy Medicare and Medicaid beneficiaries without running afoul of the Beneficiary Inducements Civil Monetary Penalty (CMP) or the Anti-Kickback...more

OIG Issues HHS Fiscal Year 2016 Work Plan

The Work Plan describes more than 100 initiatives, including 43 new initiatives for the upcoming year. On November 2, the Department of Health and Human Services (HHS) Office of the Inspector General (OIG) issued its...more

Non-Group Health Plan MMSEA Section 111 Reporting Updates

The Centers for Medicare and Medicaid Services (CMS) recently made several announcements regarding Medicare, Medicaid, and SCHIP Extension Act (MMSEA) Section 111 reporting for Non-Group Health Plans (NGHPs). Originally...more

OIG Work Plan Midyear Update Adds Activities Related to Medicare Part D and Medicaid Rebates

The update to the Fiscal Year 2015 Annual Work Plan includes new initiatives that may affect pharmaceutical companies and Medicare Part D payors and pharmacies. Annually, the Department of Health and Human Services...more

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