PODCAST: Williams Mullen's Benefits Companion - SECURE 2.0 Act - More Relief for Plan Administrators
Recent Tenth Circuit Decision in John Q Hammons Fall Following SCOTUS’ Decision in Siegel v. Fitzgerald Could Result in Significant Refunds for Certain Chapter 11 Debtors
Nuts and Bolts of a Repayment Investigation: Keys to Conducting Investigations Under the 60-Day Repayment Rule
Hospice Audit Series: The Latest Developments and Strategies for Success in the Ever-changing Audit Landscape
Gentiva, the renamed former Kindred at Home, agreed to pay $19.4 million to resolve claims that its predecessor company, Kindred at Home and related companies, violated the False Claims Act by retaining overpayments for...more
The 60-day Refund Rule, created by the 2010 Affordable Care Act, requires providers to report and return Medicare and Medicaid overpayments within 60 days of identifying them. See Section 1128J(d) of the Social Security Act,...more
On August 21, 2023, the New York State Office of the Medicaid Inspector General (OMIG) issued updated guidance regarding its Self-Disclosure Program (Updated Guidance). In the final days of 2022, New York’s Department of...more
On August 21, 2023, the New York State Office of the Medicaid Inspector General (OMIG) published an update to its self-disclosure program. The update allows for two (2) types of self-disclosures: (i) an Abbreviated Statement...more
The New York Office of the Medicaid Inspector General (OMIG) recently announced updates to its Self-Disclosure Program in response to feedback from Medicaid stakeholders after its revised posting in January 2023. OMIG revised...more
On August 21, 2023, the New York State Office of the Medicaid Inspector General (OMIG) announced updates to the Medicaid overpayment self-disclosure program, which now includes an abbreviated process for reporting and...more
On February 24, 2023, CMS issued a proposed rule updating its Medicaid Disproportionate Share Hospital (DSH) program regulations as a result of legislative changes made by the Consolidated Appropriations Act (CAA) of 2021....more
Report on Medicare Compliance 31, no. 35 (September 26, 2022) - For the third time in about 2 1/2 years, hospitals or other providers that are part of Dartmouth-Hitchcock Health, a large health system in New Hampshire,...more
This post is the third and final installment of our blog series on the proposed regulations published by the New York State Office of Medicaid Inspector General (OMIG). The proposed regulations would repeal the current Part...more
Medicare, Medicaid, and pharmacy benefit manager (PBM) audits can result in substantial losses for pharmacies. If auditors uncover evidence—or apparent evidence—of overpayments, not only can they initiate recoupments, but...more
On August 17, 2022, the Centers for Medicare and Medicaid Services (CMS) issued a bulletin (Bulletin) to states addressing potentially inappropriate cost-based proposals and practices related to governmental ambulance...more
In the July 13, 2022 issue of the New York State Register, the New York State Office of Medicaid Inspector General (OMIG) published a proposed regulation that it will likely adopt this fall. The proposed regulation will add...more
The US Department of Health and Human Services, Office of Inspector General (OIG) recently transmitted a memorandum to the Center for Medicaid and CHIP Services detailing the findings of the Massachusetts state auditor's...more
On August 13, 2021, the U.S. Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”), in a much-anticipated decision, unanimously reversed rulings by the U.S. District Court for the District of Columbia...more
On June 29, 2021, the Department of Justice (DOJ) announced a settlement with California skilled nursing facility operator Plum Healthcare Group LLC and facility Azalea Holdings LLC dba McKinley Park Care Center (Plum) to...more
The 340B Program has gained national attention over the last decade, in part due to the opportunities it provides to generate revenue for participating entities without risk of significant enforcement penalties for...more
Report on Medicare Compliance 30, no. 22 (June 14, 2021) - A Colorado radiation therapy provider has agreed to pay $3.569 million in a civil monetary penalty settlement with the HHS Office of Inspector General (OIG). ...more
Report on Medicare Compliance 30, no. 17 (May 3, 2021) - In a new provider compliance audit, the HHS Office of Inspector General (OIG) said Visiting Nurse Association of Maryland (VNA) received overpayments of $2.1...more
Last week, HHS released eleven modified Frequently Asked Questions (FAQs) regarding payments distributed to providers via the CARES Act Provider Relief Fund. The FAQs cover audits and overpayments, sharing funds with...more
Breaking News- New Leadership at the FTC- •President Joseph R. Biden designated Federal Trade Commission (“FTC”) Commissioner Rebecca Kelly Slaughter as Acting Chair of the FTC . •As Commissioner, Chairwoman...more
Report on Medicare Compliance 29, no. 15 (April 20, 2020) - Maury Regional Medical Center in Tennessee has agreed to pay $1.7 million to settle false claims allegations over MS-DRG coding, the U.S. Attorney’s Office for...more
On June 17, 2019, the U.S. District Court of the District of Massachusetts rejected Massachusetts General Hospital’s (MGH) request to dismiss a qui tam complaint alleging that the teaching hospital fraudulently overbilled...more
On December 31, 2018, the Center for Medicaid and CHIP Services issued a notice indicating that CMS was altering its prior audit guidance for Medicaid Disproportionate Share Hospital (DSH) audits that had previously been...more
On October 26, 2018, the Centers for Medicare and Medicaid Services (“CMS”) released for viewing a proposed rule that includes significant changes for Medicare Advantage organizations (“MAOs”), Part D prescription drug plan...more
The OIG's April 2018 Work Plan update added six new items to its active list of scheduled audits, inspections, and evaluations. The OIG indicates its intention to review beneficiary access to drugs under Part D, as well as...more