News & Analysis as of

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 – 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

OIG Releases Report on Medicaid Fraud Control Units

The Department of Health and Human Services (HHS) Office of Inspector General (HHS-OIG) has released its Fiscal Year (FY) 2013 Annual Report (Report) on the performance of the Medicaid Fraud Control Units (MFCU)...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

HHS OIG Reports Findings on 340B Contract Pharmacy Program

Program often fails to pass through savings to uninsured patients and creates risk of diversion and duplicate discounts. As a condition of payment for covered outpatient drugs by Medicaid, manufacturers must enter into...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

OIG Reveals Pervasive Problems in Federal Drug Discounting Program

The 340B drug pricing program was created by Congress in 1992 to make prescription medicines more available to low-income and indigent patient populations. The program has been, and likely will continue to be, fertile ground...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 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 Plans to Fight Fraud, Waste, and Abuse While Promoting Quality, Safety, and Value in 2014

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released its Work Plan for Fiscal Year 2014 on January 31, 2014. The Work Plan provides insight into the OIG’s priorities by providing...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

OIG Releases Fiscal Year 2014 Work Plan

On January 31, 2014, the Department of Health and Human Services Office of Inspector General (OIG) released its work plan for fiscal year 2014. The work plan identifies the programs OIG will review in the upcoming year. The...more

OIG: Housing Placement Arrangement for Seniors Does Not Give Rise to Sanctions

The HHS Office of Inspector General (OIG) recently issued a favorable Advisory Opinion (No. 14-01) regarding a contractual arrangement under which a placement agency receives a per-resident fee for referring new residents to...more

Health Reform + Related Health Policy News - January 2014, Issue 1

In This Issue: - Top News ..Congress Approves Budget Deal with Short-Term ‘Doc Fix' ..CMS “Two-Midnight” Rule delayed until March 31, 2014 ..Individuals with Canceled Insurance Policies May Apply for...more

CMS and OIG Issue Final Regulations to Extend the Stark Exception and Anti-Kickback Statute Safe Harbor for EHR Donations

On December 27, 2013, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services’ Office of Inspector General (OIG) finalized amendments to the Physician Self-Referral Law (Stark) and...more

2013 Amendments to New York’s False Claims Act

New York recently amended its False Claims Act (New York State Finance Law § 187, et seq.) (the “NY FCA”) in response to the Inspector General of the U.S. Department of Health and Human Services’ findings that the NY FCA was...more

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