On November 6, 2023, OIG released new General Compliance Program Guidance (General CPG). The General CPG applies to all individuals and entities involved in the healthcare industry. The release of the General CPG was not...more
In a press release dated September 27, 2023, the U.S. Attorney's Office in the Southern District of Texas announced that Jesus Virlar-Cadena was sentenced to serve 50 months in federal prison for his alleged role involving...more
On June 27, 2023, CMS hosted a Special Open Door Forum regarding its Review Choice Demonstration program for Inpatient Rehabilitation Facility Services (IRFs). CMS has stated that the Medicare IRF benefit continues to...more
OIG released its Semiannual Report to Congress (the Report) which summarizes the agency’s activities from October 1, 2022, through March 31, 2023 (the Reporting Period). Among other accomplishments, the Report highlights...more
This month, OIG updated its work plan to include a new Inpatient Rehabilitation Facility (IRF) Nationwide Audit. In explaining the new workstream, OIG cited high IRF error rates in other reviews and plans to determine whether...more
CMS released an FAQ document regarding marketing and communications requirements for the Part C and Part D programs. The FAQs seek to clarify rules issued by CMS in the 2023 Medicare Advantage and Prescription Drug Benefit...more
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
Last week, DOJ and HHS-OIG published its annual report regarding the Healthcare Fraud and Abuse Control (HFAC) Program (the Report). The Report summarizes the enforcement activity of DOJ and HHS and states that during Fiscal...more
7/29/2022
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Healthcare Fraud ,
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On June 6, 2022, OIG released its Semiannual Report to Congress (the Report) which summarizes the agency’s activities from October 1, 2021 through March 31, 2022 (the Reporting Period). Among other accomplishments, the...more
On February 18, 2022, Massachusetts General Hospital (MGH), the Massachusetts General Hospital’s Physician’s Organization, and Mass General Brigham Incorporated (collectively, Defendants) agreed to pay $14.6 million to...more
In December 2021, OIG issued its Semiannual Report to Congress (SAR) covering OIG’s activities for the reporting period of April 1, 2021 through September 30, 2021, as well as the entire Fiscal Year (FY) 2021 (October 1, 2020...more
On November 8, 2021, OIG released an update to the Self-Disclosure Protocol (SDP). The revised SDP includes a name change for the SDP, increased minimum amounts required to settle under the SDP, a requirement that SDP...more
On June 21, 2021, OIG released a report titled “Medicare Lacks Consistent Oversight of Cybersecurity for Networked Medical Devices in Hospitals” (OEI-01-20-00220) (the OIG Report). OIG determined that CMS’s accreditation...more
On December 3, 2020, HHS issued its fourth amendment to the Declaration for Medical Countermeasures Against COVID-19 under the Public Readiness and Emergency Preparedness Act (PREP Act). The PREP Act authorizes the Secretary...more
In its November 2020 Work Plan update, OIG announced it will begin auditing short stay inpatient hospital claims under the Two Midnight Rule, and when appropriate, recommend overpayment collections. OIG does not specify the...more
On September 22, 2020, CMS announced it will expand the Medicare Prior Authorization Model for Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) nationwide. The RSNAT Prior Authorization Model assesses whether...more
On June 22, 2020, CMS issued a press release calling for a renewed national commitment to value-based payment models for healthcare providers rather than fee-for-service models. The proclamation came as CMS also released...more
On June 4, 2020, HHS released new guidance detailing what additional data laboratories must report to HHS along with COVID-19 test results. HHS explained that the new guidance standardizes reporting requirements in an effort...more
Last week, HHS released new and modified existing Frequently Asked Questions (FAQs) regarding payments distributed to providers via the CARES Act Provider Relief Fund. Importantly, the CARES Act requires that providers...more
On April 10, 2020, HHS announced it is beginning the delivery of an initial $30 billion in relief funding to providers as part of the $100 billion provider relief fund in the Coronavirus Aid, Relief, and Economic Security...more
On March 6, 2020, President Trump signed H.R. 6074, the Coronavirus Preparedness and Response Supplemental Appropriations Act (the Act) into law (Public Law 116-123). The legislation, which was introduced on March 4 and...more
On November 8, 2019, the Department of Justice (DOJ) announced a settlement with a New York hospital for $12.3 million in connection with alleged improper overlapping and concurrent urology surgeries performed by one...more
On September 18, 2019, OIG released a report assessing a sample of drug manufacturers participating in the Medicaid Drug Rebate Program to identify the primary areas in which they make assumptions when calculating average...more
On June 26, 2019, the United States District Court for the Northern District of Ohio granted a motion to dismiss a qui tam lawsuit against HCR ManorCare Inc. and its subsidiaries, including Heartland Hospice Services, LLC...more
On June 17, 2019, CMS announced a voluntary settlement program for Inpatient Rehabilitation Facility (IRF) appeals pending at the Medicare Administrative Contractor (MAC), the Qualified Independent Contractor, the Office of...more