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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
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
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
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
Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity.
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
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
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
The HHS Office of Inspector General has targeted hospitals for fraud enforcement. It is one of the OIG’s most important initiatives because of the impact it could have on reducing health care costs....more
To paraphrase a famous quote, "Those who do not learn from history are doomed to repeat it," and providers who ignore the significance of the federal government's healthcare fraud enforcements efforts in 2012 do so at their...more
The HHS OIG has released a report recommending that CMS grant the Medicare Drug Integrity Contractor (MEDIC) wider latitude in pursuing potential fraud and abuse by Medicare Advantage plans. The report found that the MEDIC,...more
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
When it comes to healthcare fraud enforcement, the government knows how to target its resources. It is estimated that at least 25 percent of all claims paid by Medicare are improper. The government understands the...more
Providers can voluntarily disclose potential fraud with respect to Federal health care programs — Medicare, Medicaid, and potentially private insurers to the extent Federal or state funds are involved — by following the...more
The financial recoveries for healthcare fraud are staggering. The Justice Department and Health and Human Services (Office of Inspector General (“OIG”) and Centers for Medicare and Medicaid Services (“CMS”)) regularly...more
As its title makes clear, the August 2012 report “Questionable Billing by Community Mental Health Centers” (the Report) by the U.S. Department of Health and Human Services Office of Inspector General (OIG) demonstrates its...more
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