News & Analysis as of

Health Care Providers Cooperative Compliance Regime

Dentons

Ep. 3 - OIG’s New Approach to Compliance Guidance

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In November 2023, the United States Health & Human Services Officer of Inspector General (“OIG”) issued new compliance program guidance for the healthcare industry, referred to as the General Compliance Program Guidance...more

Dentons

Ep. 1 - Have You Created a Compliance Culture?

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Is your organization’s culture complimenting your healthcare compliance program? Does it enhance and maximize your program’s effectiveness?  Or, is your culture secretly sabotaging your compliance efforts?...more

The Volkov Law Group

HHS-OIG Guidance — Chock Full of Compliance Best Practices and Strategies (Part II of III)

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Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...more

Akerman LLP - Health Law Rx

Compliance Officers: Read the New OIG General Compliance Program Guidance!

The Office of Inspector General of the U.S. Department of Health and Human Services (the OIG) recently released an updated General Compliance Program Guidance document (GCPG). The GCPG has been anticipated since the OIG...more

Manatt, Phelps & Phillips, LLP

HHS OIG Unveils First New Compliance Program Guidance for Health Care Stakeholders Since 2008

The Big Picture - Many health care stakeholders have long relied on the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) guidance regarding an effective compliance program when...more

Troutman Pepper

DOJ's New Voluntary Self-Disclosure Policy Raises More Questions Than It Answers

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On February 22, 2023, the Department of Justice (DOJ) issued a press release highlighting the new Voluntary Self-Disclosure (VSD) Policy for U.S. Attorney’s Offices (USAOs). The DOJ developed this policy, which is applicable...more

Robinson & Cole LLP

Health Law Diagnosis - OIG Compliance Updates

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The Office of Inspector General (OIG) recently issued two notable compliance updates, of which health care organizations should take note as the COVID-19 public health emergency ends and regulatory compliance activities ramp...more

Manatt, Phelps & Phillips, LLP

OMIG Proposes Omnibus Regulations Impacting Medicaid Providers’ and Plans’ Compliance Obligations

On July 13, 2022, the New York State Office of Medicaid Inspector General (OMIG) published proposed rules in the New York State Register to implement provisions of the State Fiscal Year 2020-2021 Enacted Budget and the...more

Quarles & Brady LLP

Civil Rights Compliance for Hospitals in Wisconsin

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Happy holidays, Wisconsin health care providers! As a gift to all of you, earlier this month, the Wisconsin Department of Health Services (DHS) and Department of Children & Families (DCF) released their new joint guidance for...more

Wiley Rein LLP

Compliance Roadblocks: Tackling Information Blocking Challenges in Health Care

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On May 1, 2020, the U.S. Department of Health and Human Services (HHS) signaled a paradigm shift in the manner in which patient electronic health information (EHI) is accessed, used, and disclosed....more

Ballard Spahr LLP

COVID-19 Outbreak Creates Disclosure and Due Diligence Challenges

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Disclosure to municipal bond investors of material risks stemming from the coronavirus outbreak presents a serious concern in the municipal securities industry. This is particularly true in certain sectors, including bonds...more

Morgan Lewis - Health Law Scan

Mere Differences of Judicial Opinion Emerge to Muddle Healthcare Providers False Claims Act Exposure for Mere Differences of...

In the Care Alternatives False Claims Act (FCA) appeal, a panel of the US Court of Appeals for the Third Circuit on March 4 reversed the summary judgment granted to hospice provider Care Alternatives at the district court,...more

Bricker Graydon LLP

CMS announces reduced psychiatric hospital burden with new survey process

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On January 13, 2020, the Centers for Medicare & Medicaid Services (CMS) announced a new streamlined survey and certification process for psychiatric hospitals as part of the agency’s “Patients over Paperwork” initiative. ...more

Troutman Pepper

Lessons From the DOJ: How Recent Guidance and Cases Can Help You Avoid Government Interference With Your Business

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The initiation of a government investigation is often a stressful and anxiety-producing event for a health care company. The Department of Justice (DOJ) is known for its aggressive investigation and prosecution of health care...more

Bricker Graydon LLP

U.S. hospitals will continue to grapple with GDPR compliance in 2019

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When the European Union’s General Data Protection Regulation (GDPR) became effective on May 25, 2018, many US-based hospitals struggled to determine whether they were subject to the GDPR and, if so, what they must do to...more

Burr & Forman

Reviewing and Updating Your Corporate Compliance Plan

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As 2018 winds down and 2019 kicks off, it is wise to review various aspects of your practice to ensure everything is up to date and continues to operate in compliance with applicable laws. One area of focus for such review is...more

Bradley Arant Boult Cummings LLP

OIG Publishes New Tool for Measuring Compliance Program Effectiveness

The Department of Health and Human Services, Office of Inspector General (OIG), in conjunction with the Health Care Compliance Association, recently released a resource document to help healthcare organizations measure the...more

Epstein Becker & Green

New York State Office of the Medicaid Inspector General Releases Guidance on Compliance Program Reviews

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In the 1990s, as part of the Federal Sentencing Guidelines, the U.S. Sentencing Commission developed for the first time the criteria upon which it will view an organization’s compliance program to be “effective.” In October...more

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