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OIG Approves Net Profit–Based Bonuses for Employed Physicians

The US Department of Health and Human Services Office of Inspector General (OIG) recently released Advisory Opinion No. 23-07, in which OIG approved a proposed arrangement to pay employed physicians bonuses based on net...more

Saved by the Bell? Telehealth Remains Largely Intact When PHE Ends

Healthcare providers are scrambling to understand the impacts of the May 11 expiration of the COVID-19 public health emergency (PHE). Luckily for most telehealth providers, the outlook of their operations post-PHE is...more

OIG Lauds UPIC Program and Recommends Expansion, Additional Targeting of Medicaid Providers

On October 3, the Office of Inspector General (OIG) of the US Department of Health and Human Services issued a report titled “UPICs Hold Promise to Enhance Program Integrity Across Medicare and Medicaid, But Challenges...more

OIG Issues Telehealth Special Fraud Alert on the Heels of DOJ Takedown

The recent increase in use of telehealth as a care modality has been important to patients and providers alike, with significant benefits for public health. However, with the growing mainstream acceptance of virtual care, the...more

OIG Launches New Resource Page Featuring Telehealth

Perhaps signaling the increasing likelihood of a permanent telehealth solution for the Medicare program, the Office of Inspector General for the US Department of Health and Human Services (OIG) has established a “Featured...more

February Fast Break Recap: Risk Adjustment and Liability

Last month, we had an engaging Fast Break session covering the growing importance of risk adjustment in various health insurance programs and novel government theories of liability associated with risk adjustment reporting....more

July Fast Break Recap: Fourth Circuit AKS Case Enforcement Analysis

We hope you were able to join us for our July Fast Break on the US Court of Appeals for the Fourth Circuit's recently affirmed $114 million judgment in United States v. Mallory. If not, you missed a great session, featuring...more

Tele-Tuesday: OIG Clarifies Stance on Telehealth Fraud Scrutiny

The US Department of Health and Human Services Office of Inspector General (OIG), the Department of Justice (DOJ), and other federal regulators have grown increasingly concerned about the use of telehealth technologies by...more

HHS Regulatory Sprint Crosses the Finish Line: New Stark and Anti-Kickback Rules Forecast Big Changes for Patients and Value-Based...

Powerfully illustrating the efforts of the US Department of Health and Human Services (HHS) to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare...more

HHS to Exercise Enforcement Discretion in Response to CMS Telehealth Waiver

As we noted in our previous Health Law Scan blog CMS Issues Program Instructions for Medicare Telehealth Waiver, CMS issued program instructions on March 17 to implement the Medicare telehealth waiver in response to the...more

OIG and CMS Coordinate Seismic Change to Fraud and Abuse Laws—What It Means for the Health Industry

Highlighting the US Department of Health and Human Services’ (HHS) efforts to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare and Medicaid...more

OIG Report on Hospice Vulnerabilities: Recommendations Receive Lukewarm Support from CMS

The Office of Inspector General Portfolio Report is a rehash of the watchdog agency’s 2006–2016 findings on quality of care concerns and program integrity issues. The report, which garnered some critical press attention for...more

Retail Pharmacy: OIG Signals It’s Okay to Reward Again

OIG Advisory Opinion paves the way for expanded retailer reward programs. The US Department of Health and Human Services Office of Inspector General (OIG) issued an advisory opinion on September 7 that provides important...more

OIG Issues Critical Medical Review Report of Hospice GIP

The report shows significant lapses in 2012 GIP service claims and recommends that CMS implement additional oversight and enforcement options....more

OIG Recommends Greater Scrutiny for Hospice Services in ALFs

The OIG’s recently released study examining Medicare hospice claims from 2007 to 2012 calls for targeted reviews of hospices that receive a high proportion of their payments for care in assisted living facilities....more

CMS Final Rule Adds More Arrows but also Demonstrates Restraint

CMS reconsiders $10 million bounties for reporting of regulatory violations. On December 5, the Centers for Medicare & Medicaid Services (CMS) finalized a rule (the Final Rule) that expands its program integrity and...more

OIG Proposes Rules on Free Transportation, Hospital Gainsharing, and Other Access to Care Arrangements

The proposed rule to give providers more protections to promote beneficiary access to care solicits significant industry input. On October 2, the Department of Health and Human Services (HHS) Office of Inspector...more

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