News & Analysis as of

Healthcare Compliance Audits

Proskauer - Health Care Law Brief

No Surprises Here!  CMS Audit Uncovers Non-Compliance by Aetna in Calculation and Disclosure Requirements Under the No Surprises...

In a recent audit, the Centers for Medicare & Medicaid Services (“CMS”) uncovered non-compliance by Aetna Health Inc. of Texas (“Aetna”) in calculating key payment information for air ambulance services under the No Surprises...more

Foley & Lardner LLP

Compliance Compass: The Erlanger Complaint – A Cautionary Reminder About the Importance of FMV

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Although most health care lawyers and compliance officers who review and analyze physician compensation understand that fair market value (FMV) is important, the nuances around FMV are sometimes missed....more

Ankura

OIG Testimony Puts a Spotlight on Clinical Documentation and Payer Risk

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In recent testimony before the United States House Committee on Energy and Commerce Subcommittee on Oversight and Investigations, Christi A. Grimm, Inspector General of the Department of Health and Human Services (HHS)...more

Ankura

Spring Cleaning: Why Now Is the Perfect Time to Assess Your Compliance Program

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Spring is a time for renewal. Cleaning out your home, refreshing your life and at work, reassessing your compliance program to ensure that it is operating effectively and efficiently. As federal and state governments continue...more

NAVEX

Addressing Cybersecurity Expectations in Healthcare

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2024 is shaping up to be a very active year for regulatory and enforcement developments in the healthcare industry – developments that concern not just hospitals and nursing facilities, but many non-healthcare companies as...more

Gardner Law

Highlights from OIG’s New Compliance Program Guidance

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The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) released an important new compliance resource in November 2023. The HHS OIG’s new General Compliance Program Guidance (GCPG) is intended...more

Health Care Compliance Association (HCCA)

In This Month’s E-News: December 2023

Report on Research Compliance 20, no. 12  (December 2023) Although the National Science Foundation (NSF) allowed more than half the costs questioned by auditors for its Office of Inspector General (OIG), the California...more

Freiberger Haber LLP

Securities Act Claims Dismissed as Time-Barred and Otherwise Insufficient

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On March 20, 2018, the United States Supreme Court decided Cyan, Inc. v. Beaver County Employees Retirement Fund, in which it unanimously held that the Securities Litigation Uniform Standards Act of 1998 does not strip state...more

Baker Donelson

OIG Hospital Compliance Audits: Is Your Number Up? Are You Ready?

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In its Work Plan for Fiscal Year 2012, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) announced it would begin reviews of Medicare payments to hospitals to determine compliance...more

Burr & Forman

Meaningful Use Audits: Proactive Tips for Success

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For health care professionals who began accepting Meaningful Use incentive money at the outset of availability under the Medicare option in 2011, the year 2015 is an important year. If the provider has met all core...more

Womble Bond Dickinson

Is Your HIPAA Compliance Program Ready for the FTC?

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Everyone in healthcare knows that the next round of HIPAA audits is coming. Covered entities and business associates have long been advised to review and update their HIPAA security risk analyses, have business associate...more

Robinson+Cole Data Privacy + Security Insider

OIG report spurs OCR to announce phase 2 audits

On September 29, it was revealed that the HHS Office for Civil Rights (OCR) will commence Phase 2 of its HIPAA audit program in “early 2016.” OCR’s revelation regarding the Phase 2 audits, which had been the subject of...more

Robinson+Cole Data Privacy + Security Insider

OCR announces launch of Phase 2 of HIPAA audits

Although the Office for Civil Rights (OCR) has indicated in the past that it would start its next round of HIPAA audits, apparently it means business now. In the wake of an Inspector General report that the OCR was merely...more

Holland & Knight LLP

HHS Issues Proposed 340B Program Omnibus Guidance: Five Things to Watch

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The 340B Drug Pricing Program (340B Program), established by Section 602 of the Veterans Health Care Act of 1992, is administered by the Health Resources and Services Administration (HRSA) of HHS. The 340B Program requires...more

Orrick, Herrington & Sutcliffe LLP

Don’t Wait for It; Recent HIPAA Enforcement Action Signal More to Come in Phase 2 Audits

Officials at the U.S. Department of Health and Human Services Office of Civil Rights (HHS OCR) have recently selected a vendor to conduct the second wave of HIPAA audits. These so-called “Phase 2 Audits” are set to commence...more

BakerHostetler

340B Guidance: Eight Key Points Covered Entities Should Consider

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On August 27, 2015, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), released the 340B Drug Pricing Program Omnibus Guidance (Guidance). Referred to...more

Thomas Fox - Compliance Evangelist

Lessons from GSK in China – Internal Controls, Auditing and Monitoring

One of the questions that GSK will have to face during the next few years of bribery and corruption investigations is how an allegedly massive bribery and corruption scheme occurred in its Chinese operations? The numbers went...more

Epstein Becker & Green

CMS Identifies Key Priorities for 2014 Compliance Reviews of Qualified Health Plans in the Federally Facilitated Marketplace

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At a Centers for Medicare & Medicaid Services ("CMS") teleconference titled "Compliance Reviews in the Federally-Facilitated Marketplace" ("FFM"), which was held on April 10, 2014, CMS representatives discussed the agency's...more

BakerHostetler

DOL Continues Effort to Subject TRICARE Providers to Federal Equal Employment Opportunity Audits

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Previously, we reported how the U.S. District Court for the District of Columbia found in UPMC Braddock v. Harris that providers of healthcare services are subject to federal equal employment opportunity mandates applicable...more

McDermott Will & Emery

Preparing a Hospital or Health System for Sale or Partnership Transactions – Part Two

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The consolidation trend in hospital and health systems continues. To address perceived inefficiencies and quality of care issues, hospitals are attempting to form larger enterprises to create scale, expand geographically,...more

The Volkov Law Group

Hospitals: Audits And Compliance

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Hospitals are under intense scrutiny. The federal government knows that one sure way to reduce healthcare costs is to get hospitals to lower their costs. Hospitals feel the pinch given the need to generate revenue but know...more

McNees Wallace & Nurick LLC

DOL Audits Of Employer-Sponsored Group Health Plans Now Include Healthcare Reform Compliance

The U.S. Department of Labor (the "DOL") has recently enhanced its enforcement activities with respect to group health plans by significantly increasing the number of audits it is conducting. In addition, the DOL's audit...more

The Volkov Law Group

Audits, Audits And More Audits: Life In The Healthcare Industry

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Healthcare suppliers and service providers live in a regulated world. They are constantly under audit scrutiny. Sometimes federal agencies (i.e private contractors) conduct the audits; other times state agencies conduct the...more

Mintz - Health Care Viewpoints

Utilizing the HIPAA audit protocols as a compliance tool By Kimberly J. Gold

Originally published in Compliance Today on December 1, 2012. ..Covered entities are now subject to privacy and security audits by OCR. ..OCR published audit protocols regarding its standards for such audits. ...more

Epstein Becker & Green

HHS Publishes Roadmap for HIPAA Audits .

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One of the less well-known provisions of the Health Information Technology for Economic and Clinical Health (or "HITECH") Act[1] is the requirement that the U.S. Department of Health and Human Services ("HHS") periodically...more

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