On April 5, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule (CMS-4201-F) regarding the Medicare Advantage (MA) and Part D programs. The Final Rule includes changes related to various aspects of...more
4/10/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Continuity of Care ,
Department of Health and Human Services (HHS) ,
Final Rules ,
Health Care Providers ,
Medical Necessity ,
Medicare Advantage ,
Medicare Part D ,
OIG ,
Regulatory Agenda ,
Regulatory Requirements ,
Two-Midnight Rule
OIG periodically makes updates to its Integrity Agreement (IA) and Corporate Integrity Agreement (CIA) model language. It is important for healthcare organizations – even those not subject to a CIA – to monitor changes to...more
On September 22, 2021, OIG Principal Deputy Inspector General Christi Grimm delivered a keynote speech to the American Health Law Association (AHLA) Fraud and Compliance Forum. Consistent with her remarks this spring at the...more
10/11/2021
/ AHLA ,
Compliance ,
Coronavirus/COVID-19 ,
Enforcement ,
Fraud ,
List of Excluded Individuals/Entities (LEIE) ,
Medicaid ,
Medicare ,
Nursing Homes ,
OIG ,
Request For Information
On September 15, 2021, OIG posted Advisory Opinion 21-12, regarding a proposed arrangement involving a program to offer certain free items and services to patients who experience specific complications after undergoing...more
On July 7, 2021, OIG posted Advisory Opinion No. 21-07 relating to a proposed arrangement between a Medigap Plan and a Preferred Hospital Organization (PHO). The proposed arrangement involves (i) a discount on policyholder’s...more
Last week, OIG posted Advisory Opinions Nos. 21-03, 21-04, and 21-05 relating to three near-identical arrangements between Medigap plans and Preferred Hospital Organizations (PHOs). The arrangements involve (i) a discount on...more
On September 21, 2020, the HHS Office of Civil Rights (OCR) announced a $1.5 million settlement with Athens Orthopedic Clinic, a Georgia orthopedic clinic, to settle potential violations of the Health Insurance Portability...more
On August 24, 2020, CMS released a notice extending its timeline to publish its final rule with significant changes to the Stark regulations that was proposed in October 2019. Previously, CMS had indicated that it intended...more
On July 1, 2020, OIG published an advisory opinion regarding a discount medical plan organization (DMPO). A DMPO is not an insurer but contracts with providers who agree to reduce their fees for the DMPO’s members. Under...more
On April 30, 2019, DOJ’s Criminal Division announced the release of an updated version of guidance previously issued in February 2017 regarding the evaluation of corporate compliance programs (Revised DOJ Compliance...more
In March, OIG released its annual Medicaid Fraud Control Units (MFCUs) report for Fiscal Year (FY) 2018. MFCUs investigate and prosecute Medicaid provider fraud and patient abuse and neglect and are jointly funded by the...more
Last month, OIG released its Medicaid Fraud Control Units (MFCUs) report for Fiscal Year (FY) 2017. MFCUs investigate and prosecute Medicaid provider fraud and patient abuse and neglect and are jointly funded by the federal...more
On December 29, 2017, OIG issued a favorable advisory opinion interpreting the application of the gainsharing civil monetary penalty provision (Gainsharing CMP) and the Anti-Kickback Statute in connection with a proposed...more
On March 27, 2017, in conjunction with the Health Care Compliance Association (“HCCA”) annual Compliance Institute (“CI”), the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”) released...more