News & Analysis as of

Office of the Inspector General Permissive Exclusion Authority

Proskauer - Health Care Law Brief

Another Unique Integrity Agreement Signals a Trend towards HHS-OIG’s Comfort with a Belt and Suspenders

In recent years, there have been only a handful of corporate integrity agreements (“CIAs”) and integrity agreements (“IAs”) that have included a “conditional exclusion release” of the Office of the Inspector General for the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"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

Davis Wright Tremaine LLP

New Exclusion Rule on the Horizon

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

Sheppard Mullin Richter & Hampton LLP

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

McDermott Will & Emery

New OIG Exclusion Regulations About to Go into Effect

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

Baker Donelson

Despite Uncertain Future of ACA, OIG Issues Final Rule Revising Permissive Exclusion Authority

Baker Donelson on

On January 12, 2017, the Department of Health and Human Services (HHS), Office of Inspector General (OIG) published a final rule expanding its permissive exclusion authority while also codifying certain statutory changes made...more

Baker Donelson

OIG Updates Permissive Exclusion Criteria – Suggests Compliance Programs Are Expected

Baker Donelson on

On April 18th, the Office of Inspector General (OIG) issued updated guidance describing the factors it will consider in determining whether to exercise its permissive authority to exclude individuals and entities from federal...more

Parker Poe Adams & Bernstein LLP

New Exclusion Guidance Includes Presumption of Compliance Plan

Section 1128 of the Social Security Act (42 U.S.C. 1320a–7) (available here) established mandatory and permissive authority for exclusion of health care providers from Federal health care programs based on provider conduct. ...more

Benesch

New OIG Exclusion Guidance

Benesch on

On April 18, 2016, the Department of Health and Human Services Office of the Inspector General (“OIG”) issued revised criteria for implementing permissive exclusion authority. These revisions are a non-binding policy...more

Saul Ewing LLP

U.S. Department of Health and Human Services Updates Criteria for Permissive Exclusion Under Section 1128(b)(7) of the Social...

Saul Ewing LLP on

The HHS-OIG issued new guidelines on April 18, 2016 regarding the Secretary's exercise of the Department's permissive exclusion authority pursuant to Section 1128(b)(7) of the Social Security Act. The HHS-OIG's new guidance...more

Arnall Golden Gregory LLP

OIG Releases Revised Policy Statement on Exclusion Authority

On April 18, 2016, the Office of Inspector General of the Department of Health and Human Services (OIG) released a revised policy statement on its exclusion authority, entitled Criteria for Implementing Section 1128(b)(7)...more

King & Spalding

OIG Issues Revised Policy Statement Regarding Permissive Exclusion

King & Spalding on

On April 18, 2016, the Office of Inspector General of the United States Department of Health and Human Services (“OIG”) issued a revised policy statement containing the new criteria that OIG intends to use in implementing its...more

McDermott Will & Emery

OIG Issues New Exclusion and CIA Guidance

McDermott Will & Emery on

On April 18, 2016, Inspector General Daniel R. Levinson announced the publication of updated guidance on how the Office of Inspector General (OIG) makes decisions about using its permissive exclusion authority and requiring...more

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