News & Analysis as of

Office of the Inspector General Dept. of Health and Human Services

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

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

Free Or Discounted Local Transportation: To Offer It Or Not?

On December 7, 2016, the Department of Health and Human Services, Office of the Inspector General (the “OIG”) published a final rule (the “Final Rule”) (that took effect January 6, 2017) that, among other things, added a new...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

When to Use the OIG’s Self Disclosure Protocols

by Ruder Ware on

The HHS Office of Inspector General offers providers an opportunity to self-disclose certain violations in exchange for avoiding some of the more draconian penalties that may otherwise apply under applicable regulations. ...more

Destination Medicine: Not Just for the Rich and Famous

by BakerHostetler on

OIG okays providing modest hotel and meal accommodations for rural and financially needy patients. The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued an advisory opinion...more

HHS-OIG Publishes Resource on Compliance Program Effectiveness

by Alston & Bird on

On March 27, 2017, the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG) announced a 52-page resource guide, Measuring Compliance Program Effectiveness: A Resource Guide, aimed at helping...more

OIG Issues Favorable Advisory Opinion Relating to Free Hotel Lodging and Cafeteria Meals for Qualifying Patients

by Arnall Golden Gregory LLP on

On March 3, 2017, the U.S. Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 17-01. The Opinion relates to a request by an academic medical center (the “Requestor”) consisting...more

Excluded Party Cases Dominate OIG Published Self Disclosure Settlements

by Ruder Ware on

In 2013, the HHS Office of Inspector General issued revised protocols outlining the process through which health care providers are able to self-disclose and resolve potential liability under the OIG’s civil monetary penalty...more

"Trends in Corporate Integrity Agreements Reflect New HHS OIG Guidance on Use of Exclusion Authority"

2016 was a year of change for the Department of Health and Human Service's Office of Inspector General's (OIG) approach to corporate integrity agreements (CIA). The OIG began to use its new model CIA format and applied its...more

New Exclusion Rule on the Horizon

by Davis Wright Tremaine LLP on

On January 12, 2017, the Department of Health and Human Services Office of Inspector General (“OIG”) published a final rule which provides guidance on its new and expanded bases for permissive exclusion from federal health...more

New OIG Exclusion Authority Rule Set To Go Into Effect on March 21, 2017

On January 12, 2017, just a week prior to President Trump’s Inauguration, the Department of Health and Human Service (HHS) Office of Inspector General (OIG) published a final Rule (Rule) regarding one of its most important...more

OIG Warns Public: Do Not Fall for “OIG Hotline” Scammers

by Reed Smith on

The HHS Office of Inspector General (OIG) is warning the public that scammers are spoofing the OIG’s hotline telephone number to obtain personal information from individuals that then can be used to steal money from the...more

New OIG Exclusion Regulations About to Go into Effect

by McDermott Will & Emery on

The Office of Inspector General (OIG) recently published a final rule regarding its exclusion authorities. The final rule goes into effect March 21, 2017, and expands OIG’s authority to exclude certain individuals and...more

OIG Announces Drug Pricing and Reimbursement Web Portfolio

by Dorsey & Whitney LLP on

On February 17, 2017 the Office of the Inspector General (OIG) posted a Drug Pricing and Reimbursement Web portfolio on its website that, according to the OIG announcement, “pulls together the HHS OIG’s body of work since...more

HHS Report Acknowledges Complications of Fraud and Abuse Statutes on Value-Based Arrangements

by King & Spalding on

HHS posted a report to Congress on its website in August 2016 that responds to the requirements in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) to offer legislative and regulatory suggestions regarding the...more

OIG Publishes Online Portfolio Highlighting its Body of Work on Drug Pricing and Reimbursement

For several years now, the public outcry over the issue of drug pricing and reimbursement has increased in frequency and fervor. At least one government agency wants you to know that it has been listening and wants to help...more

OIG Finalizes Expanded Exclusion Authorities under ACA (Updated)

by Reed Smith on

On January 12, 2017, the Office of Inspector General (OIG) of the Department of Health and Human Services issued the final rule implementing its statutory authority under the Affordable Care Act (ACA) to expand the exclusion...more

Fraud and Abuse Investigations Should be Taken Very Seriously

by Burr & Forman on

According to the United States Government, fraud and abuse recovery has an excellent return for each investment dollar spent. According to the Health Care Fraud and Abuse Control (HCFAC) Program Report,released by the...more

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