Office of the Inspector General

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OIG Criticizes CMS’s 16-Year Delay in Issuing Regulations; CMS Yawns

Turns out it’s not just health care providers that notice CMS’s foot-dragging. Last Thursday the Office of Inspector General (OIG) of Health & Human Services (HHS) published its report on what CMS has done—or rather, has not...more

Medigap Policy Contract with Preferred Hospital Networks Approved by OIG

On August 18, 2014, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued another advisory opinion approving a licensed insurance broker’s proposal to establish a preferred hospital network...more

HUD OIG report critical of asset repositioning fee calculations

HUD’s Office of Inspector General (OIG) issued an audit of HUD last week pertaining to awards of asset repositioning fees (ARF), the funds that public housing authorities (PHAs) may receive in connection with demolishing or...more

Implications on Pharmacies of Recent OIG Advisory Opinion on Per-Fill Fees

The U.S. Department of Health & Human Services, Office of Inspector General (OIG) recently issued an advisory opinion regarding a proposed arrangement by a specialty pharmacy (Requestor) to pay local pharmacies a per-fill fee...more

News from the Health Law Gurus™

News from the Health Law Gurus™ is a weekly summary of notable health law news from around the country with helpful links to related content. Check back every week for the latest health law news stories....more

Client Alert - The Rules of the Game Change As ICE Targets Employers

The year 2009 marked a dramatic change in Immigration and Customs Enforcement’s (ICE) workforce enforcement strategy. Up until 2008, ICE focused its enforcement efforts almost exclusively on illegal workers. For instance, ICE...more

Specialty Pharmacy Per-fill Fee Rejected by OIG

On August 15, 2014, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued a “negative” opinion regarding a specialty pharmacy’s proposal to pay a per-fill fee to local pharmacies for support...more

The Increasingly Murky World of 340B: What’s Next?

For the past 18 months, health care providers and the pharmaceutical industry have been hoping for some clarity regarding 340B Drug Discount Program operations. But things just keep getting murkier....more

OIG Advisory Opinion Approves Medigap Insurer’s Plan to Use Preferred Hospital Network

On August 25, 2014, the OIG released an advisory opinion declining to impose civil monetary penalties on a Medicare Supplemental Health Insurance – or Medigap – insurer that planned to discount inpatient hospital deductibles...more

OIG's Rejection of Payments for Prescription Transfers Leaves Questions about Central Fill Pharmacy Arrangements.

The U.S. Department of Health & Human Services, Office of Inspector General (OIG) recently refused to bless a specialty pharmacy's request to pay a per-prescription fee to retail pharmacies for "support services" to be...more

HHS OIG Issues Report on Questionable Billing for Medicaid Pediatric Dental Services

What you need to know: The Office of Inspector General for the US Department of Health & Human Services recently published the results of its study on Louisiana dentists who may be providing unnecessary dental...more

OIG Okays Medigap Insurer’s Arrangement for Discount on Inpatient Deductibles

Last Monday the Office of Inspector General (OIG) of Health & Human Services posted an advisory opinion (No. 14-07) allowing a Medigap insurance company to strike a deal with hospitals for discounts—even waivers—of the...more

OIG Rejects Specialty Pharmacy Request to Pay “Per-Fill” Payents to Retail Pharmacies

In OIG Advisory Opinion 14-06, the Office of Inspector General (OIG) concluded that payment by a specialty pharmacy to a retail pharmacy on a “per-fill” basis for services provided by the retail pharmacy could violate the...more

AHA Renews Complaints about OIG Hospital Compliance Reviews

The American Hospital Association (AHA) has renewed its complaints about OIG “hospital compliance reviews.” Last Thursday AHA Executive Vice President Rick Pollack sent a letter to Health & Human Services Secretary Burwell...more

OIG Rejects Pharmacy’s Plan for Per-Fill Referral Fees, Or Be Careful What You Ask For

Advisory Opinion No. 14-06, issued August 15, addressed a plan by the chain to reimburse local pharmacies for referrals of patients in need of specialized drugs that the local pharmacies did not dispense. In the scenario...more

OIG Finds Risk of Abuse in Specialty Pharmacy’s Per-Fill Fee Proposal

In an Advisory Opinion posted August 15, 2014, the Office of Inspector General (“OIG”) concluded that a proposed arrangement by a specialty pharmacy (“Requestor”) might generate prohibited remuneration under the Federal...more

News from the Health Law Gurus™

Chinese Hackers Infiltrate Health System Network Affecting 4.5 Million Individuals – Community Health Systems, Inc. (“CHS”) reported this week that the information of approximately 4.5 million individuals has been affected by...more

New Guidance on Contractor Self-Disclosure

The Health and Human Services (HHS) Office of Inspector General (OIG) provides health care providers an opportunity to disclose potential violations of certain Federal civil and criminal laws in relation to HHS contracts or...more

Nursing Home Abuse and Neglect Compliance Trails Federal Requirements

The Department of Health and Human Services Officer of Inspector General (“OIG”) released a report this month titled, “Nursing Facilities’ Compliance with Federal Regulations for Reporting Allegations of Abuse and Neglect.”...more

Health Law Wire: OIG Report on Nursing Home Compliance with Federal Regulations for Reporting Allegations of Abuse or Neglect...

The Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services released a report and recommendations for nursing facilities to develop and implement written policies related to reporting...more

OIG Issues “Special Fraud Alert” on Lab Payments for Specimen Processing and Data Registry

On June 25, 2014, the OIG issued a Special Fraud Alert addressing compensation paid by laboratories to referring physicians. This Special Fraud Alert supplements prior OIG guidance which emphasizes that providing free or...more

OIG Report Takes Issue With Oversight of Security Controls for Electronic Health Records

HHS Office of Inspector General (OIG) recently released a report concluding that the entity responsible for overseeing the testing and certification process for electronic health records (EHRs) did not fully ensure that...more

Laboratory Payments to Physicians for Specimen Processing Present Substantial Risk of Fraud and Abuse

The United States Office of Inspector General (“OIG”) recently issued a “Special Fraud Alert” focusing on two potentially illegal trends that it has detected in arrangements between laboratories and their referring...more

Discount Drug Program Passes OIG Scrutiny

On July 28th, 2014, the Department of Health and Human Services, Office of Inspector General (OIG) released favorable advisory opinion 14-05, concluding that a pharmaceutical manufacturer’s direct-to-patient discounted, cash...more

OIG Approves Manufacturer’s Direct-to-Patient Discount Sales Program

The Office of Inspector General (“OIG”) recently posted an Advisory Opinion approving a pharmaceutical manufacturer’s direct-to-patient product sales program. While this Advisory Opinion cannot be relied upon by anyone other...more

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