The OIG recently issued a report (A-01-12-00507) concerning the potential financial impact to Medicare Part A if CMS established a hospital transfer payment policy for early discharges to hospice care. The OIG explained that...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 December 31, 2012 the U.S. Department of Health and Human Services Office of Inspector General ("OIG") issued a favorable Advisory Opinion No.12-22 for a hospital cardiology group compensation arrangement that includes a...more
Making its most strongly worded statement to date, the Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert on Physician-Owned Entities on March 26, 2013, calling...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
On January 7, 2013, the Department of Health and Human Services Office of Inspector General (“OIG”) posted a favorable advisory opinion concerning an existing co-management arrangement (“Arrangement”) between a large, rural,...more
In Advisory Opinion 12-22, the OIG permitted a hospital to make payments to a cardiology group as part of a co-management agreement that for all intent and purpose are gainsharing payments. The extent to which this represents...more
Hospitals across the country have been actively seeking to align physician interests with the interests of the hospital, in order to provide high quality patient care in a more coordinated and efficient manner. Many hospitals...more
On January 7, 2012, the OIG posted Advisory Opinion No. 12-22 to address a co-management arrangement between a hospital and physicians that is designed to align incentives by offering compensation based on quality, service,...more
On January 7, 2013, the HHS OIG released Advisory Opinion 12-22 concerning a rural hospital's (Hospital) proposal to pay a cardiology group (Group) a performance bonus for achieving certain patient service, quality and cost...more
On January 7, 2013, HHS OIG published a favorable advisory opinion on a management arrangement between a hospital and a cardiology group related to the provision of certain cardiac catheterization services at the hospital. ...more
The OIG recently posted an Advisory Opinion which concluded that a hospital's proposal to provide free access to an electronic interface between the hospital and area physicians for laboratory and diagnostic services was not...more
In OIG Advisory Opinion 12-20, the OIG determined that a proposed arrangement (the “Proposed Arrangement”) by a hospital (the “Requestor”) would not constitute grounds for the imposition of sanctions under the Anti-Kickback...more
The HHS Office of Inspector General (OIG) recently released its 2012 Compendium of Unimplemented Recommendations (the “Compendium”), a report that summarizes significant monetary and nonmonetary recommendations as a result of...more
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