News & Analysis as of

OIG Issues Compendium of Unimplemented Priority Recommendations

On March 18, 2014, the OIG released its Compendium of Priority Recommendations (Compendium), which lists 25 broad “Priority Recommendations” for achieving “cost savings, improve program management, and ensure quality of care...more

The 2014 OIG Work Plan: Select Provisions Applicable to Physician Practices

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently issued its 2014 Work Plan outlining its intended review activities of HHS Programs for 2014. This article summarizes certain...more

Health Care Update

In This Issue: Implementation of the Affordable Care Act; Other Congressional and State Initiatives; Other Health Care News; and Upcoming Hearings and Markups. Excerpt from Implementation of the Affordable Care...more

OIG 2014 Work Plan – Hospice

This article represents another installment of a series of articles that will outline the OIG’s activities, as discussed in the 2014 work plan, for a specific industry sector – hospice. For 2014, the OIG’s activities...more

OIG 2014 Work Plan – Skilled Nursing Facilities

Recently, the Department of Health and Human Services Office of the Inspector General (the “OIG”) released its work plan for 2014. The work plan provides stakeholders in the health care industry with a broad overview of the...more

Halifax Settles Stark Damages for $85 Million

Halifax Hospital Medical Center and Halifax Staffing, Inc. (collectively, “Halifax”) have agreed to pay $85 million to settle allegations that Halifax compensated a group of physicians in a manner not permitted by the Stark...more

OIG Targets Integrated Hospital Systems With Recommended Changes to Medicare’s 3-Day DRG Payment Window

On February 19, 2014, the Office of the Inspector General of the United States Department of Health and Human Services (“OIG”) released a report recommending two changes in the Medicare Diagnosis Related Group (“DRG”)...more

OIG Approves Medigap Policy Contracts with Preferred Hospital Networks

On February 20, the U.S. Department of Health & Human Services, Office of the Inspector General (OIG) released Advisory Opinion 14-02, concerning the use of preferred hospital networks as part of certain Medicare Supplemental...more

OIG Reports on Expansion of DRG Window

The OIG recently posted a report in which it recommended expanding the Diagnosis Related Group (DRG) payment window. In the February 2014 report (OEI-05-12-00480) (the “Report”), available here, the OIG analyzed both...more

Rx for Fraud: Electronic Health Records

By pursuing a mandate to digitize medical records, the federal government hopes to improve patient care and reduce costs. But recent reports by the Office of the Inspector General (OIG) indicate that fraud prevention policies...more

Health Law Alert: OIG Issues Special Fraud Alert on Physician-Owned Distributorships

On March 26, 2013, the Department of Health & Human Services Office of Inspector General (OIG) issued its latest in a line of “Special Fraud Alerts” that address the application of the Federal anti-kickback statute to...more

2014 OIG Work Plan: Impact of Provider-Based Status on Medicare Billing

The 2014 OIG Work Plan includes the following: Policies and Practices. We will determine the impact of subordinate facilities in hospitals billing Medicare as being hospital based (provider based) and the extent to...more

2014 OIG Work Plan: Oversight of Hospital Privileging

The 2014 OIG Work Plan includes the following: Quality of Care and Safety. We will determine how hospitals assess medical staff candidates prior to granting initial privileges, including verification of credentials and...more

HHS OIG 2014 Work Plan Highlights Grants Management and Allowable Cost Initiatives

The U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) released its Fiscal Year 2014 Work Plan (“2014 Plan”) on January 31, 2014. The OIG releases a work plan annually to identify new and...more

The Strike Force Approach To Combatting Health Care Fraud

The U.S. Department of Justice (DOJ), Health and Human Services Office of Inspector General (HHS-OIG) and other federal and state agencies are aggressively prosecuting health care fraud and related offenses through a strike...more

OIG's 2014 Work Plan: A Roadmap to Key OIG Fraud and Abuse Priorities

The Department of Health and Human Services, Office of the Inspector General (OIG) released its Fiscal Year (FY) 2014 Work Plan on January 31, 2014. While the OIG usually releases its work plan in October of each year, in...more

OIG Publishes Report Identifying Issues With 340B Contract Pharmacy Arrangements

On February 5, 2014, the Office of the Inspector General (OIG) for the Department of Health and Human Services (HHS) published a report (OIG Report) describing the results of a survey it had conducted of the use of contract...more

The Healthcare Industry And Chief Compliance Officers

The healthcare industry has been an innovative leader in developing compliance tools and strategies. They have come by it honestly – prosecutors and HHS-OIG have been pounding on pharmaceutical companies, medical device...more

OIG 2014 Work Plan Focuses On Compounded Pharmaceuticals Reimbursed By Medicare

The Office of Inspector General for the U.S. Department of Health and Human Services (“OIG”) included two items in its recently-released 2014 Work Plan indicating a new focus on the quality and safety of compounded...more

OIG Reports on Contract Pharmacy Arrangements in the 340B Program

On February 4, 2014, the U.S. Department of Health and Human Services, Office of the Inspector General (OIG) issued a memorandum report regarding contract pharmacy arrangements in the 340B Program. In its report, OIG found...more

Court Dismisses POD Lawsuit Against OIG

On February 5, 2014, a federal court dismissed a challenge to the U.S. Department of Health and Human Services’ Office of Inspector General’s (“OIG”) March 26, 2013 Special Fraud Alert (“2013 SFA”) on physician-owned...more

Health Care Self-Disclosure Protocols – Is It Worth It To Self-Report?

In recent years the federal government has aggressively investigated and prosecuted pharmaceutical companies and health care providers for possible violations of anti-fraud, anti-kickback and other laws. These efforts have...more

OIG Issues Report on Contract Pharmacy Arrangements Under the 340B Program

According to a recently posted report by the Department of Health and Human Services Office of Inspector General (OIG), covered entities utilizing contract pharmacies to dispense drugs under the 340B Drug Pricing Program (the...more

HHS-OIG Criticizes 340B Drug Discount Program

I recently posted that 2014 is expected to be a year of major developments in the 340B Drug Discount Program, with HRSA receiving enhanced funding, stepping up audit activity, and drafting regulations in response to criticism...more

Healthcare Enforcement Actions and Trends: 2013 Overview

The Department of Justice (DOJ) and the Office of Inspector General for the U.S. Department of Health and Human Services continued aggressive enforcement of the healthcare industry in 2013. Officials employed a variety of...more

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