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Incentives Civil Monetary Penalty

Venable LLP

Federal Efforts to Incentivize States to Promulgate False Claims Statutes

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The federal False Claims Act (FCA) is widely regarded as a powerful tool to punish fraud against the federal government. Since 1986, the federal government has recovered more than $75 billion from FCA settlements and...more

Robinson+Cole Health Law Diagnosis

Advisory Opinion 22-16: OIG Declines to Impose Sanctions for Arrangement Involving Provision of Gift Cards to Patients for...

On August 19, 2022, the Office of Inspector General (OIG) published Advisory Opinion 22-16 (Advisory Opinion) in which it declined to impose sanctions for an arrangement under which the requestor provides gift cards to...more

BakerHostetler

All Eyes on Us - the Latest FTC Case Involves Contact Lenses plus an Important Lesson About Incentivized Reviews

BakerHostetler on

Up until now, most of the FTC’s law enforcement involving the Contact Lens Rule (Rule) has focused on sellers of cosmetic or decorative lenses. Indeed, safety concerns about decorative lenses were newsworthy in 2010, when...more

King & Spalding

OIG Provides Additional Guidance Regarding Application of Administrative Enforcement Authorities to Arrangements Directly...

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On May 24, 2021, OIG provided additional guidance in the form of an FAQ as to whether an offer or provision of cash, cash-equivalent, or in-kind incentives or rewards to Federal health care program beneficiaries who receive...more

Seyfarth Shaw LLP

New Safe Harbors In A Storm of Risk and Regulations: A Review of the OIG’s Proposed Changes to the Federal Anti-Kickback Laws

Seyfarth Shaw LLP on

In an effort to modernize and clarify a statute that looms large in the minds of health care providers across the nation, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) recently...more

Bass, Berry & Sims PLC

Sprinting to Coordinated Care: Healthcare Industry Urges Stark Law Relief as OIG Solicits Feedback on Changes to the Anti-Kickback...

August 24, 2018 marked a busy day for the U.S. Department of Health & Human Services' (HHS) self-designated "Regulatory Sprint to Coordinated Care," an initiative aimed at dismantling the regulatory barriers to providers...more

Holland & Knight LLP

Request for Information: Aligning AKS and CMP with Coordinated Care Initiatives

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On Aug. 24, 2018, the Office of Inspector General (OIG) issued a request for information (RFI) regarding the Anti-Kickback Statute (AKS) and Beneficiary Inducement provisions of the Civil Monetary Penalty (CMP) law. The...more

Dorsey & Whitney LLP

OIG Seeks Public Input on Anti-Kickback Statute and Beneficiary Inducements CMP as part of the “Regulatory Sprint to Coordinated...

Dorsey & Whitney LLP on

The Department of Health and Human Services’ (HHS) Office of Inspector General (OIG) has identified the anti-kickback statute (AKS) and beneficiary inducements civil monetary penalty (CMP) as potential barriers to...more

Bass, Berry & Sims PLC

Tennessee Rule Change: Prohibition on Prescription Transfer Incentives

Bass, Berry & Sims PLC on

Tennessee pharmacies can no longer offer patients financial rewards in exchange for the transfer of the patient's prescriptions. Effective February 20, 2017, the Tennessee Board of Pharmacy enacted a new rule providing that...more

Pierce Atwood LLP

Pierce Atwood Environmental Regulatory Compliance Calendar

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Federal - Notice of Availability of the Environmental Protection Agency’s Two Updated Chapters in the EPA Air Pollution Control Cost Manual - EPA is making two finalized chapters of the EPA Air Pollution Control...more

Proskauer Rose LLP

New OSHA Rule Requires Employers To Reevaluate Certain Workplace Policies

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On May 12, 2016, the Occupational Safety & Health Administration (OSHA) published a final rule regarding reporting injuries and illnesses in the workplace and protecting employees who make those reports. The new rule expands...more

BCLP

What Employers Need to Know about OSHA’s New Reporting and Anti-Retaliation Regulations

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The Occupational Safety and Health Administration (OSHA) recently implemented new regulations that will impact covered employers beginning on August 10, 2016. Specifically, these new regulations will require electronic...more

Baker Donelson

Limited Modifications in Final ACO Fraud and Abuse Waivers Most Notably Include Cut of Gainsharing CMP Waiver

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Nearly four years after publishing their joint interim final rule with comment period, effective November 2, 2011 (IFC), the OIG and CMS (Agencies) have finalized the waivers of various fraud and abuse laws in the context of...more

King & Spalding

OIG Issues Favorable Advisory Opinion on FQHC Limited Issuance of Gift Cards

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In a recent favorable advisory opinion, the OIG reviewed a Federally qualified health center’s (FQHC) proposal to offer $20 grocery store gift cards to certain patients in capitated managed care plans as an incentive for such...more

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