Report makes no formal recommendations, but OIG notes that lengths of stay and frequency of general inpatient care are issues requiring further scrutiny....more
Hospitals continue to be under the Department of Justice-HHS/Office of Inspector General microscope. DOJ-OIG is a potent combination and carry with them the threat of criminal prosecution, civil false claims enforcement and...more
On April 10, 2013, the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services Office of Inspector General (“OIG”) published parallel proposed rules revising, respectively, the Stark...more
On April 17, 2013, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released an updated Provider Self-Disclosure Protocol (Protocol) that supersedes and replaces the protocol published in the...more
On Wednesday, April 17, 2013, the Department of Health and Human Services’ Office of Inspector General (OIG) released an updated Self-Disclosure Protocol (SDP) governing the process by which health care providers can...more
The U.S. Department of Health & Human Services, Office of Inspector General (the “OIG”) issued a Special Fraud Alert (“Alert”) on March 26, underscoring its heightened focus on fraud and abuse risks posed by physician-owned...more
The Centers for Medicare & Medicaid Services and the U.S. Department of Health and Human Services issued proposed rules that would extend the sunset date for the Stark Law exception and the federal Anti-Kickback Statute safe...more
On April 17, 2013, the Office of Inspector General of the Department of Health and Human Services (“OIG”) released an Updated Provider Self-Disclosure Protocol (“SDP”). The Updated SDP replaces OIG’s original Provider...more
OIG touts substantial benefits of disclosing, provides greater detail for different types of disclosures, and captures 15 years of OIG Self-Disclosure Protocol experience....more
In This Issue: Leading the News; Implementation of the Affordable Care Act (ACA); Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; Other Health Care News; and Hearings and...more
On April 10, 2013, CMS and the HHS Office of Inspector General (OIG) each published proposed rules to extend the sunset dates for the Stark exception and anti-kickback statute safe harbor permitting donations of EHR software...more
On March 26, 2013, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert entitled “Physician-Owned Entities.” The Alert is consistent with an ongoing theme of concern...more
The Office of the Inspector General (OIG) for the Department of Health and Human Services announced and solicited comments to proposed rule changes to the Electronic Health Records Safe Harbor (EHRSH) under the federal...more
On April 3, 2013, the Department of Justice (DOJ) and Intermountain Health Care, Inc. (Intermountain) entered into a settlement agreement resolving Intermountain’s potential liability under the Stark Law and False Claims Act....more
On Wednesday, April 10, 2013, the Centers for Medicare & Medicaid Services (“CMS”) and the Office of the Inspector General (“OIG”) of the Department of Health and Human Services published complementary proposed rules in the...more
Alert notes attributes and practices that produce substantial fraud and abuse risk. On March 26, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) issued its "Special Fraud...more
Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity. ...more
On March 26, 2013, the Office of the Inspector General (“OIG”) of the Department of Health and Human Services issued its first Special Fraud Alert in three years. The new Alert focuses on physician-owned distributorships...more
On March 15, HHS OIG issued updated guidelines regarding how it will evaluate State false claims acts. Under the Deficit Reduction Act of 2005, States became eligible for financial incentives (i.e., retaining a larger share...more
New state health care fraud recovery statistics reinforce that both the federal and state governments remain committed to health care fraud enforcement and demonstrate that their efforts are paying dividends. Earlier this...more
Last year was another busy year in health care fraud enforcement. In 2012, the Office of Inspector General for the Department of Health and Human Services (HHS-OIG) reported total expected recoveries of $6.9 billion from all...more
The Department of Health and Human Services’ Office of Inspector General (OIG) recently published two reports finding Medicare improperly paid providers millions of dollars for incarcerated beneficiaries and unlawful aliens...more
It is always important to consider how different parts of the government handle voluntary disclosures. The FCPA enforcement initiative has been largely the result of the voluntary disclosure process, and the government...more
The HHS Office of Inspector General has targeted hospitals for fraud enforcement. It is one of the OIG’s most important initiatives because of the impact it could have on reducing health care costs....more
To paraphrase a famous quote, "Those who do not learn from history are doomed to repeat it," and providers who ignore the significance of the federal government's healthcare fraud enforcements efforts in 2012 do so at their...more
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