News & Analysis as of

Office of the Inspector General

Hospital and its Clinic Agree to $34 Million Settlement to False Claims Act Allegation that Compensation to Oncologists Violated...

Last week, the Department of Justice (DOJ) entered into a $34 million settlement with Mercy Hospital Springfield (“Hospital”) of Springfield, Missouri, and its affiliate Mercy Clinic (“Clinic”). The settlement resolves an...more

OIG Report Continues Criticism of CFPB Enforcement Data Security Practices

by Ballard Spahr LLP on

On May 15, 2017, the Federal Reserve Office of Inspector General – which also oversees the CFPB – released a report finding deficiencies in the CFPB Office of Enforcement’s (Enforcement) processes for securing sensitive...more

CMS Gamed System to Identify Hospitals Gaming System?

by Faegre Baker Daniels on

You can’t make this stuff up. When CMS conducted a study to identify hospitals that game the quality data reporting system, it used an approach that made the data reporting look better than it actually was. That bottom line...more

Why Healthcare and Life Sciences Companies Need to Step Up Their Compliance Efforts in Advance of a U.S. Government Investigation

by Hogan Lovells on

In this hoganlovells.com interview, Hogan Lovells partner Gejaa Gobena discusses how the perception of compliance, remediation, and self-disclosure has evolved in the eyes of government prosecutors from how they factor at...more

Repayment and Self Disclosure of Known Overpayments

by Ruder Ware on

The 60-day repayment rule adopted as part of the Affordable Care Act is a very strong arrow in the quiver of federal enforcement agencies. Under the 60-day rule a known overpayment can become a False Claim if it is not repaid...more

Stark Law: What Providers Should Know About New CMS Form

by Polsinelli on

The Centers for Medicare and Medicaid Services (CMS) has finalized Form CMS-10328 (the SRDP Form), a new OMB-approved information collection instrument that must be used by providers and suppliers utilizing the Stark Law...more

The OIG 2017 Work Plan Includes Focus on Hospitals - Corridors Newsletter April 2017

by Poyner Spruill LLP on

The U.S. Department of Health and Human Services (DHHS) Office of Inspector General (OIG) has issued its Work Plan for Fiscal Year 2017. The annual Work Plan provides a summary of new, revised, and continuing reviews for DHHS...more

Privacy Tip #85 – OIG Warns Consumers of Phone Call Scams by OIG Imposters

Phone call scams are on the rise. In addition to scam artists posing as employees of utility companies (see Privacy Tip #84), the Office of the Inspector General (OIG) has issued a warning to consumers about a phone scam...more

How Effective Is Your Compliance Program? New OIG and DOJ Guidance for Measuring the Effectiveness of Your Corporate Compliance...

by Dorsey & Whitney LLP on

Compliance programs are an important tool for health care providers. Compliance programs help to prevent fraud, waste and abuse, create a mechanism for catching problems early, and effective compliance programs can also...more

OIG Publishes Compliance Program Effectiveness Guide

by Arnall Golden Gregory LLP on

On March 27, 2017, the HHS Office of Inspector General (OIG) issued a document entitled “Measuring Compliance Program Effectiveness: A Resource Guide.” Published in conjunction with the Health Care Compliance Association...more

OIG issues report on CFPB contract award controls; updated work plan includes evaluation of CFPB’s supervisory corrective action...

by Ballard Spahr LLP on

The Office of Inspector General for the Fed and CFPB recently issued an audit report entitled “The CFPB Can Strengthen Contract Award Controls and Administrative Processes.” The objective of the OIG’s audit was to assess the...more

OIG to Audit FAA Drone Waiver Processes

The Office of the Inspector General (OIG) of the U.S. Department of Transportation (DOT) has announced an audit of the Federal Aviation Administration’s (FAA) “approval and oversight processes” for Part 107 waivers for...more

DOJ vs. OIG: Analysis of Recently Issued Federal Compliance Documents

by Polsinelli on

Within just weeks of each other, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) issued separate documents that health care organizations may use to...more

Measuring the Effectiveness of a Compliance Program

by Thomas Fox on

How does one measure effectiveness? In Wichita, Kansas, in 1876, when it came to town a Deputy Sheriff, the final measure was the elected government. On this day in that year, the town’s Commissioners voted not to extend the...more

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

OIG Releases “Resource Guide” Regarding Measuring Compliance Program Effectiveness

by King & Spalding on

On March 27, 2017, in conjunction with the Health Care Compliance Association annual Compliance Institute, HHS OIG released a Resource Guide for the healthcare industry to facilitate the consideration of potential options for...more

Compliance 2.0 and the Significance of HHS OIG’s 2017 Resource Guide: “Measuring Compliance Program Effectiveness”

by King & Spalding on

On March 27, 2017, in conjunction with the Health Care Compliance Association (“HCCA”) annual Compliance Institute (“CI”), the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”) released...more

OIG and HCCA Offer Suggestions for Measuring Health Organization Compliance Program Effectiveness

by Reed Smith on

The OIG and the Health Care Compliance Association (HCCA) recently held a roundtable where the discussion focused on a broad range of ideas regarding how health care organizations can measure their compliance program...more

Corporate Law & Governance Update - April 2017

by McDermott Will & Emery on

The following developments from the past month offer guidance on corporate law and governance law as they may be applied to nonprofit health care organizations: OVERSIGHT OF CORPORATE CULTURE - A significant emerging...more

Civil Forfeiture Under Fire – Part II

by Ballard Spahr LLP on

In this post, we consider the Department of Justice’s (DOJ) Office of the Inspector General report (OIG Report), released on March 29, 2017, evaluating the DOJ’s oversight of its cash seizure and forfeiture operations. This...more

New OIG Rules Change Patient Incentive Program Landscape: Where Are the Limits Now?

by McDermott Will & Emery on

With health care becoming more consumer-driven, health care providers and health plans are wrestling with how to incentivize patients to participate in health promotion programs and treatment plans. As payments are...more

Blog: OIG and HCCA Release Compliance Program Effectiveness Resource Guide

by Cooley LLP on

On March 27, 2017, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) and the Health Care Compliance Association (HCCA) released Measuring Compliance Program Effectiveness: A Resource Guide...more

New Safe Harbor Permits Some Free Transportation to Patients

by Ruder Ware on

A new safe harbor was recently issued by the Health and Human Services (HHS) Office of Inspector General (OIG) that permits eligible health care providers to offer free or discounted transportation to established patients....more

Effective Internal Compliance Programs

by Bryan Cave on

Effective compliance programs continue to gain importance. Across all industries, it is imperative that meaningful compliance programs are in place and that they are regularly assessed to account for new risks and changes in...more

New Guidance Offers Deep Dive Into Compliance Issues

Following up on DOJ’s recent memo on “Evaluation of Corporate Compliance Programs,” the Office of Inspector General at the U.S. Department of Health and Human Services released its own compliance program evaluation memo last...more

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