Anti-Kickback Statute, HHS | JD Supra Law News

CMS and OIG Propose Changes to the Electronic Health Records Exception and Safe Harbor

by Thompson Coburn LLP on 4/25/2013

On April 10, 2013, the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services Office of Inspector General (“OIG”) published parallel proposed rules revising, respectively, the Stark...more

The Top 10 Things You Need To Know About The OIG’S Revised Self-Disclosure Protocol

by Laurence Freedman, Laura Laemmle-Weidenfeld | Patton Boggs LLP on 4/23/2013

On Wednesday, April 17, 2013, the Department of Health and Human Services’ Office of Inspector General (OIG) released an updated Self-Disclosure Protocol (SDP) governing the process by which health care providers can...more

OIG Special Fraud Alert Labels Physician-Owned Distributorships (PODs) as “Inherently Suspect”

by Dennis Diaz, Sarah S. Fallows | Davis Wright Tremaine LLP on 4/22/2013

The U.S. Department of Health & Human Services, Office of Inspector General (the “OIG”) issued a Special Fraud Alert (“Alert”) on March 26, underscoring its heightened focus on fraud and abuse risks posed by physician-owned...more

HHS Extends Sunset Date for Stark Exception and Anti-Kickback Safe Harbor for EHR Donations

by Daniel F. Gottlieb | McDermott Will & Emery on 4/19/2013

The Centers for Medicare & Medicaid Services and the U.S. Department of Health and Human Services issued proposed rules that would extend the sunset date for the Stark Law exception and the federal Anti-Kickback Statute safe...more

HHS OIG Issues Revised Self-Disclosure Protocol

by Holly Barker, Albert Shay, Howard Young | Morgan Lewis on 4/18/2013

OIG touts substantial benefits of disclosing, provides greater detail for different types of disclosures, and captures 15 years of OIG Self-Disclosure Protocol experience....more

CMS, OIG Propose to Extend EHR Stark Exception and Anti-Kickback Safe Harbor

by King & Spalding on 4/16/2013

On April 10, 2013, CMS and the HHS Office of Inspector General (OIG) each published proposed rules to extend the sunset dates for the Stark exception and anti-kickback statute safe harbor permitting donations of EHR software...more

OIG Special Fraud Alert on Physician-Owned Distributorships

by James Henry, Kristen A. Larremore | Bradley Arant Boult Cummings LLP on 4/16/2013

On March 26, 2013, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert entitled “Physician-Owned Entities.” The Alert is consistent with an ongoing theme of concern...more

OIG Proposes Amendments to the Electronic Health Records Safe Harbor

by Paul Koob, Dee Spagnuolo | Ballard Spahr LLP on 4/11/2013

The Office of the Inspector General (OIG) for the Department of Health and Human Services announced and solicited comments to proposed rule changes to the Electronic Health Records Safe Harbor (EHRSH) under the federal...more

CMS and OIG Propose Extension of Federal Stark Exception and Anti-Kickback Safe Harbor for Electronic Health Record Donations

by Ropes & Gray LLP on 4/11/2013

On Wednesday, April 10, 2013, the Centers for Medicare & Medicaid Services (“CMS”) and the Office of the Inspector General (“OIG”) of the Department of Health and Human Services published complementary proposed rules in the...more

OIG Issues Special Fraud Alert for Physician-Owned Entities

by Darby C. Allen, Donna S. Clark | BakerHostetler on 4/5/2013

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued a Special Fraud Alert expressing concern that physician-owned entities "that derive revenue from selling, or arranging for the...more

Hospitals and Doctors Beware: OIG Issues Special Fraud Alert on Physician-Owned Entities

by Kathleen McDermott | Morgan Lewis on 3/28/2013

Alert notes attributes and practices that produce substantial fraud and abuse risk. On March 26, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) issued its "Special Fraud...more

OIG Places Fraud and Abuse Spotlight on Physician-Owned Entities

by Bruce D. Armon | Saul Ewing LLP on 3/28/2013

Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity. ...more

OIG Issues Special Fraud Alert on Physician-Owned Distributorships (PODs)

by Ropes & Gray LLP on 3/28/2013

On March 26, 2013, the Office of the Inspector General (“OIG”) of the Department of Health and Human Services issued its first Special Fraud Alert in three years. The new Alert focuses on physician-owned distributorships...more

Health Care Enforcement in 2012: A Year in Review

by Hope Foster, Samantha Kingsbury, Tracy Miner, Jessica Sergi, Stephanie Willis | Mintz Levin - Health Law on 2/26/2013

Last year was another busy year in health care fraud enforcement. In 2012, the Office of Inspector General for the Department of Health and Human Services (HHS-OIG) reported total expected recoveries of $6.9 billion from all...more

The Healthcare Industry And The Voluntary Disclosure Process

by Michael Volkov on 2/21/2013

It is always important to consider how different parts of the government handle voluntary disclosures. The FCPA enforcement initiative has been largely the result of the voluntary disclosure process, and the government...more

Major New Jersey Health System Pays $12.6 Million To Settle False Claims Act Suit Alleging Physician Kickback Scheme

by Henry E. Hockeimer, Jr., Evan Krick, Dee Spagnuolo | Ballard Spahr LLP on 1/31/2013

Federal prosecutors recently announced a $12.6 million False Claims Act (FCA) settlement with a major New Jersey health system to resolve allegations that the system paid outside physicians in order to increase referrals....more

OIG Advisory Opinion Sheds Light On Pay-For-Performance Relationships Between Hospitals And Physicians

by Darby C. Allen, Donna S. Clark | BakerHostetler on 1/20/2013

On January 7, 2013, the HHS OIG released Advisory Opinion 12-22 concerning a rural hospital's (Hospital) proposal to pay a cardiology group (Group) a performance bonus for achieving certain patient service, quality and cost...more

OIG: Cardiac Catheterization Arrangement Between Hospital and Physicians Not Subject to Sanctions

by King & Spalding on 1/18/2013

On January 7, 2013, HHS OIG published a favorable advisory opinion on a management arrangement between a hospital and a cardiology group related to the provision of certain cardiac catheterization services at the hospital. ...more

mHealth Stakeholders: Bullet List of Legal Considerations

by Duane Morris LLP on 5/22/2012

You are a device maker, an app or software developer, a potential investor, a healthcare provider, a healthcare payor or an insurer and you see opportunities in mobile health (mHealth). You have an idea for a revolutionary...more

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Anti-Kickback Statute › Dept. of Health and Human Services