William Mathias

William Mathias

Baker Donelson

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OIG Approves Free Lodging and Meals Under "Promotes Access to Care" Exception to Beneficiary Inducement CMP

In Advisory Opinion 17-01, published March 10, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) approved an academic medical center's proposal to provide free or reduced-cost lodging and...more

3/25/2017 - Anti-Kickback Statute Civil Monetary Penalty Federal Poverty Line Free Health-Related Services Inducements OIG

OIG Finalizes CMP Regulations, Largely as Proposed

On December 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) finalized [PDF] its proposal to update the civil monetary penalty (CMP) regulations – namely, incorporate new CMP authorities...more

12/23/2016 - Affordable Care Act Civil Monetary Penalty CMS Final Rules HHS Medicare Advantage Medicare Part D OIG Self-Disclosure Requirements

OIG Approves Another Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-11

On November 3, 2016, the OIG issued another favorable Advisory Opinion, No. 16–11, regarding an agreement between a Medigap insurer and preferred hospital network. The OIG has issued several opinions regarding similar...more

12/21/2016 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Fraud and Abuse Hospitals Medigap OIG Preferred Hospital Networks Arrangement Safe Harbors

OIG Approves Transportation Assistance Program

On October 3, 2016, the U.S. Department of Health & Human Services, Office of the Inspector General (OIG), issued an advisory opinion approving a local health care district’s proposal to cooperate with another district to...more

10/21/2016 - Advisory Opinions Anti-Kickback Statute Exemptions Free Health-Related Services Healthcare Costs HHS Local Health Care Districts OIG Outpatient Services Subsidies Underserved Locations

OIG Approves Free Vaccine Refrigeration Systems in Physician Offices

On September 16, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) released Advisory Opinion 16-09, approving a refrigerator manufacturer’s proposal to install a vaccine storage and...more

10/10/2016 - Anti-Kickback Statute Free Health-Related Services HHS Manufacturers OIG Physicians Sanctions Vaccinations

Federal Agencies Forced to Implement Huge Increases in Civil Monetary Penalties for Health Care Fraud

Thanks to section 701 of the Bipartisan Budget Act of 2015, Public Law 114–74, federal agencies have been forced to implement huge increases in penalties intended to deter health care fraud. The Federal Civil Penalties...more

9/15/2016 - Bipartisan Budget Act Civil Monetary Penalty DOJ False Claims Act (FCA) Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 Final Rules Healthcare Fraud HHS Interim Rule Stark Law

OIG Approves Hospice Payments to Nursing Facility for Dual Eligible Patients Under Medicaid Demonstration Project

On July 20, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued a favorable Advisory Opinion (16-08) [PDF] regarding payments from a hospice to a nursing facility in which a dual...more

8/12/2016 - Dual Eligibility Hospice Medicaid OIG Patients Provider Payments Skilled Nursing Facility

OIG Permits Copayment Coupon Arrangement for Statutorily Non-Covered Drug in Advisory Opinion 16-07

On June 20, 2016, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a favorable Advisory Opinion 16-07 regarding a savings card program (Card Program) under which Medicare Part D...more

7/19/2016 - Anti-Kickback Statute Coupons Federal Health Care Programs (FHCP) HHS Medicare Part D OIG Prescription Drug Coverage Prescription Drugs

OIG Approves Wholly Owned Group Purchasing Organization

In Advisory Opinion 16-06, the Office of Inspector General (OIG) approved a proposal whereby the ownership of a group purchasing organization (GPO) would be restructured so that the GPO will be wholly owned by the same...more

6/6/2016 - Anti-Kickback Statute Fraud and Abuse GPOs Health Care Providers OIG Parent Corporation Subsidiaries

CMS Announces Plans to Streamline the Stark Self-Referral Disclosure Protocol

On May 6, 2016, CMS published a notice (Notice), required under the Paperwork Reduction Act (PRA), seeking public comment on its plans to revise the information collected under the Medicare Self-referral Disclosure Protocol...more

5/26/2016 - CMS Look-Back Measurement Period Medicare Overpayment Physicians Public Comment Reporting Requirements Self-Referral Disclosure Protocol Stark Law

OIG Updates Permissive Exclusion Criteria – Suggests Compliance Programs Are Expected

On April 18th, the Office of Inspector General (OIG) issued updated guidance describing the factors it will consider in determining whether to exercise its permissive authority to exclude individuals and entities from federal...more

5/25/2016 - Burden of Proof False Claims Act (FCA) Federal Health Care Programs (FHCP) Fraud and Abuse Guidance Update Health Care Providers OIG Permissive Exclusion Authority Rebuttable Presumptions Self-Disclosure Requirements Yates Memorandum

OIG Approves Free Transportation and Lodging for Certain, Low-Income Pregnant Women - Advisory Opinion 16-02

On March 1, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-02 [PDF], approving an academic medical center's (AMC's) provision of free transportation and lodging...more

3/10/2016 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Free Health-Related Services Health Care Providers HHS Hospitals OIG Pregnancy

OIG Approves Charitable Program Providing Financial Assistance for MRIs in Advisory Opinion 15-14

On November 13, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-14. The Arrangement at issue is a charitable program designed to assist financially needy...more

2/17/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements Medicaid Medicare MRI OIG Patient Assistance Programs

OIG Approves Another Patient Assistance Program in Advisory Opinion 15-16

On December 28, 2015, the Office of Inspector General (OIG) approved another patient assistance program in Advisory Opinion 15-16. The OIG analyzed contributions to a private charitable organization under the anti-kickback...more

2/15/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements OIG Patient Assistance Programs Prescription Drugs

Charity's Patient Assistance Program Passes OIG Muster in Advisory Opinion 15-17

On December 28, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued OIG Advisory Opinion 15-17, approving a charity’s proposal to unveil a new patient assistance program dedicated to...more

2/12/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements OIG Patient Assistance Programs Prescription Drugs

OIG Issues (Another) Favorable Advisory Opinion Regarding Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-01

On January 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-01, approving yet another insurer’s proposed contract with a preferred hospital network. The...more

2/11/2016 - Advisory Opinions Anti-Kickback Statute Discounts Inducements Medicare Medigap OIG Preferred Hospital Networks Arrangement

Stark Updates Included in Final 2016 Physician Fee Schedule

With the final Medicare physician fee schedule (PFS) for 2016, the Centers for Medicare and Medicaid Services (CMS) has made a series of updates to the Stark physician self-referral regulations. The final rule is largely...more

12/2/2015 - CMS Physician Fee Schedule Physician Recruitment Agreement Physician-Owned Hospitals Stark Law Technical Standards

OIG Approves Home Health Provider's Free Introductory Visit Policy

On August 6, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a for-profit home health provider’s policy to offer free introductory visits to...more

9/28/2015 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Free Health-Related Services Health Care Providers Home Health Care OIG Sanctions

OIG Approves Limited, Free Drug Program

On August 12, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-11, approving two pharmaceutical manufacturers’ free starter drug program. Citing the limited scope...more

8/27/2015 - Anti-Kickback Statute Cancer Cost-Sharing Free Health-Related Services Free-Drug Programs Health Insurance HHS Medicare Part D OIG Patients Pharmaceutical Industry Pharmacies

Open Payments Update: End of CME Exception for Sunshine Reporting

On July 17, 2015, CMS announced updates to the Law and Policy page on the Open Payments website to provide additional guidance regarding the termination of the continuing medical education (CME) exception for reporting under...more

8/17/2015 - CME CMS Medicare Open Payments Reporting Requirements Sunshine Act

Stark Regulations: Technical Revisions

The proposed Physician Fee Schedule for CY 2016 includes multiple technical revisions to the regulations implementing the Stark law. These revisions appear to be designed to provide greater clarity and flexibility with...more

7/22/2015 - Anti-Kickback Statute CMS Commercial Leases Exceptions Physician Compensation Arrangements Physician Fee Schedule Remuneration Self-Referral Disclosure Protocol Signatures Stark Law Timeshare

Again, the OIG Approves a Medigap Policy Contract with Preferred Hospital Networks

On June 12, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-08. This opinion continues the well-established pattern of favorable advisory opinions which...more

7/3/2015 - Anti-Kickback Statute Civil Monetary Penalty Fraud and Abuse Health Insurance HHS Hospitals Medigap OIG Preferred Hospital Networks Arrangement

OIG Approves Charitable Organization's Patient Assistance Program

On May 28, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a charitable organization’s proposal to provide financial assistance to individuals with...more

6/24/2015 - Advisory Opinions Charitable Organizations Healthcare OIG Patient Assistance Programs

OIG Approves Subsidies to Medicare Beneficiaries Provided by a Clinical Research Study

On May 28, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a medical device manufacturer’s proposed arrangement to provide subsidies to certain...more

6/23/2015 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Clinical Trials HHS Medical Devices Medicare OIG Subsidies

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