Office of the Inspector General

News & Analysis as of

OIG Urges Additional Oversight to Combat Medicare Part D Fraud

Fraud, waste, and abuse in the Medicare Part D prescription drug program continue to threaten the integrity of the program and pose challenges to the federal agencies charged with its administration and oversight. Earlier...more

DOT Issues Scathing Internal Report of NHTSA’s Defect Investigation Processes

In the wake of GM’s ignition-switch, the Secretary of Transportation, Anthony R. Foxx, directed an investigation into NHTSA’s defect investigation policies and procedures. Specifically, Secretary Foxx requested that the U.S....more

It's Time to Bill Medicare: Do You Know Where Your Physicians Are?

The Department of Health and Human Services Office of Inspector General (OIG) recently reported that Medicare contractors overpaid physicians $33.4 million in incorrectly coded physician services between January 2010 and...more

Structuring Healthcare Provider Agreements for Compliance

On June 23rd, the Healthcare Law Blog discussed the Fraud Alert recently issued by the Office of Inspector General of the United States Department of Health and Human Services regarding physician compensation arrangements...more

Blog: OIG Reports Targeting Medicare Part D Fraud Issued on the Heels of National Medicare Fraud Sweep

The Health and Human Services (HHS) Office of Inspector General (OIG) released two reports yesterday related to Medicare Part D fraud. The OIG report, Ensuring the Integrity of Medicare Part D, “synthesizes numerous OIG...more

OIG Advisory Opinion 15-07: An Indicator of Clinical Trial Copayment Change?

“You scratch my back, I scratch yours” arrangements are common in business transactions. These agreements are risky in the healthcare space, however, with the potential to implicate civil and criminal sanctions. Whether...more

OIG Fraud Alert Cautions Against Sham Medical Director Arrangements

The HHS OIG recently issued a brief fraud alert (Fraud Alert) reminding physicians that inappropriate compensation arrangements may lead to enforcement actions under the federal anti-kickback statute and Civil Monetary...more

OIG Approves Charitable Organization's Patient Assistance Program

On May 28, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a charitable organization’s proposal to provide financial assistance to individuals with...more

Physicians Face Increased Anti-Kickback Enforcement Focus

It appears that the Office of Inspector General (“OIG”) now has physicians squarely in the crosshairs of one of its most powerful enforcement tools: the Anti-Kickback Statute (“AKS”). The AKS is a criminal statute with...more

OIG Fraud Alert Targets Physician Compensation Arrangements

It bears repeating so much that even the Office of Inspector General of the Department of Health and Human Services just issued a Fraud Alert on it – physician compensation arrangements are fraught with potential violations...more

Real Guidance (Finally) On the Compliance Oversight Role of Boards

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

Increased OIG Scrutiny on Medical Directorships

On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) released a Fraud Alert entitled, "Physician Compensation Arrangements May Result in Significant Liability." The Alert is an...more

OIG Approves Subsidies to Medicare Beneficiaries Provided by a Clinical Research Study

On May 28, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a medical device manufacturer’s proposed arrangement to provide subsidies to certain...more

Health Care E-Note - June 2015

In This Issue: - Why, Again, Do You Think That Worker is an Independent Contractor? - I-9 and E-Verify Compliance Practices for Temporary Labor and Contractors - Excerpt From Why, Again, Do You Think That...more

OIG Now Targeting Physician Compensation Arrangements

In a Fraud Alert issued on June 9, 2015, the U.S. Department of Health and Human Services Office of Inspector General (OIG) notified the healthcare community that physician compensation arrangements are on the OIG’s radar...more

OIG Fraud Alert Serves as Stern Warning to Physicians Regarding Compensation Arrangements

Emphasizing its continued focus on physician compensation arrangements, the OIG issued a Fraud Alert on June 9, 2015, warning that physicians risk significant penalties if medical directorships and other compensation...more

The Financial Report - Volume 4, No. 11 • June 2015 (Global)

FRB will extend high-quality liquid asset status to some state and municipal bonds. The FRB has proposed a rule that would recognize certain general obligation state and municipal bonds meeting the same liquidity...more

OIG Issues Fraud Alert to Warn Hospitals and Physicians

On June 9, 2015, the OIG issued a Fraud Alert entitled “Fraud Alert: Physician Compensation Arrangements May Result in Significant Liability”. This is just a one page letter warning hospitals and physicians by stating the...more

Miami Nursing Home To Pay Record $17M in Whistleblower Suit

A Miami-based nursing home network agreed Tuesday to pay a record $17 million to settle a False Claims Act suit brought by its former CFO, accusing it of running a kickback scheme. The case is United States of America et al...more

HRSA Proposes Civil Monetary Penalties for Drug Manufacturers that Overcharge 340B Covered Entities

The Health Resources and Services Administration (HRSA) within the U.S. Department of Health and Human Services (HHS) published a notice of proposed rulemaking impacting the 340B Drug Pricing Program (340B Program) on June...more

OIG Releases New Compliance Oversight Guidance for Health Care Governing Boards

On April 20, 2015, the U.S. Department of Health and Human Services Office of Inspector General (OIG), in conjunction with the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA)...more

OIG Targets Fraud in Physician Compensation Arrangements

Health care organizations and physicians must be cautious in structuring physician compensation arrangements so that they do not violate the Anti-Kickback Statute. The U.S. Department of Health and Human Services Office...more

OIG Fraud Alert: Physicians in the Cross Hairs

On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) issued a Fraud Alert focused on physician relationships. The Alert cautions physicians who enter into compensation arrangements...more

OIG Advisory Opinion Approves Patient Subsidies For Clinical Study

On June 4, 2015, OIG published an advisory opinion (No. 15-07) stating that it will not impose administrative sanctions on a medical device manufacturer that planned to pay for copayments and certain other costs for Medicare...more

OIG Issues Fraud Alert on Physician Compensation Arrangements

On June 9, 2015, OIG released a fraud alert titled, “Fraud Alert: Physician Compensation Arrangements May Result in Significant Liability.” Although the OIG’s enforcement of physician compensation arrangements, including...more

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