The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
3/14/2024
/ Bribery ,
Department of Health and Human Services (HHS) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
Federal Health Care Programs (FHCP) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicaid ,
Medicare Fraud ,
OIG ,
Opioid ,
Risk Assessment ,
Sentencing ,
Telemarketing ,
TRICARE ,
Wire Fraud
The Office of Inspector General (OIG) recently issued a new favorable OIG Advisory Opinion, concluding that, although the proposed arrangement (“Proposed Arrangement”) between a Medicare Supplement insurer (“MediGap Plan”)...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
2/7/2024
/ Criminal Convictions ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
False Statements ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Indictments ,
Kickbacks ,
Medicaid ,
Medicaid Drug Rebate Program ,
Medicare ,
Money Laundering ,
OIG ,
Pharmaceutical Industry ,
Physicians ,
Settlement ,
Telemedicine ,
Underpayment
The New York State Office of the Medicaid Inspector General (“OMIG”) recently updated its Self-Disclosure Guidance and Instructions, and issued updated FAQs on Self-Disclosures. The January 2024 publications supersede OMIG’s...more
In its January 16, 2023, Enforcement listserv notice, HHS’s Office of Inspector General (“OIG”) recently published Work Plan Updates for January. Although six updates were published, this article only highlights the...more
The New York Department of Health (DOH) recently announced it is accepting applications for New York Health Equity Reform: Social Care Networks regional grants. The nine regional grants will distribute a total of $500 million...more
1/24/2024
/ 501(c)(3) ,
Applications ,
Equity ,
Filing Deadlines ,
FQHC ,
Governance Standards ,
Grants ,
Healthcare Reform ,
Home and Community Based Services (HCBS) ,
MCOs ,
Medicaid ,
New York ,
State Health Departments
The New York Department of Health (DOH) recently announced it is accepting applications for the Statewide Health Care Facility Transformation Program IV. The grants will distribute $250 million to support capital projects and...more
This favorable OIG opinion relates to a proposed arrangement (“Arrangement”) regarding a one-time voluntary redemption offer to physician partners reaching age 67 to have their partnership units repurchased by the partnership...more
This favorable OIG opinion relates to Requestor who provides consulting services to physician practices and the Requestor’s proposed arrangement (“Proposed Arrangement”) to offer its current physician practice customers...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
1/12/2024
/ Anti-Kickback Statute ,
Compensation ,
Compliance ,
Department of Health and Human Services (HHS) ,
Enforcement ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Healthcare Fraud ,
Kickbacks ,
Medical Devices ,
Medicare Fraud ,
Nursing Homes ,
OIG ,
Popular ,
Risk Assessment ,
Stark Law ,
TRICARE
On January 3, 2024, the New York State Office of the Medicaid Inspector General (“OMIG”) posted its 2024 Work Plan. This is the first update since its 2019 – 2020 Work Plan and OMIG notes that the Work Plan does not reflect...more
1/10/2024
/ Auditors ,
Audits ,
Compliance ,
Durable Medical Equipment ,
Home Health Care ,
Investigations ,
Long-Term Care ,
MCOs ,
Medicaid ,
Mental Health ,
New York ,
OMIG ,
Pharmacies ,
Self-Disclosure Requirements
This favorable OIG opinion concludes that although the proposed arrangement (“Proposed Arrangement”) to subsidize Medicare cost-sharing obligations for Medicare patients in a cardiac clinical trial (“Study”) would constitute...more
The Office of Inspector General (OIG) recently issued two identical favorable OIG Advisory Opinions, concluding that, although the proposed arrangement (“Proposed Arrangement”) between a Medicare Supplement insurer (“MediGap...more
In its December 18, 2023, Enforcement listserv notice, HHS’s Office of Inspector General (“OIG”) published its Work Plan Updates for December. Although six updates were published, this article will only highlight the...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
12/8/2023
/ Anti-Kickback Statute ,
Compliance ,
Criminal Convictions ,
Department of Health and Human Services (HHS) ,
False Billing ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicaid ,
Medicare ,
OIG ,
Pharmaceutical Industry ,
Pharmacies
The Department of Health and Human Services’ (“HHS”) Office of Inspector General (“OIG”) and the Department of Justice (“DOJ”) published their joint Report on the Health Care Fraud and Abuse Control Program for Fiscal Year...more
The New York Department of Health (DOH) is seeking public comment on its revised rulemaking that seeks to establish procedures for review and approval of applications from not-for-profit corporations to be certified as a...more
OIG published its new General Compliance Program Guidance on November 6, 2023. OIG characterizes this as a reference guidance for the health care compliance community and other health care stakeholders. It is identified as...more
The New York State Office of the Medicaid Inspector General (“OMIG”) announced it will host an online engagement session on Nov. 30, 2023, to share feedback received during the April and May 2023 Provider Engagement Forums....more
The New York State Office of the Medicaid Inspector General (“OMIG”) recently issued a listserv to clarify the August 22, 2023, publication of its Abbreviated Self-Disclosure Process. No changes were announced to the...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
11/8/2023
/ Bribery ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Criminal Convictions ,
Damages ,
Department of Health and Human Services (HHS) ,
Department of Veterans Affairs ,
EMTALA ,
Enforcement Actions ,
False Claims Act (FCA) ,
Food and Drug Administration (FDA) ,
Fraud and Abuse ,
Kickbacks ,
Medicare Fraud ,
OIG ,
Penalties ,
Popular ,
Risk Management ,
Settlement ,
TRICARE
This opinion addresses a proposed arrangement (“Proposed Arrangement”) by the manufacturer of cochlear implants (“Requestor”), where the Requestor would provide certain patients who receive one of their implants with a free...more
The safe harbor cap on remuneration for patient engagement and support is adjusted annually based on changes to the consumer price index (“CPI”). 42 C.F.R. §1001.952(hh) protects specified arrangements for patient engagement...more
This opinion addresses a proposed arrangement (“Proposed Arrangement”) between a multi-specialty physician practice (“Requestor”) that employs approximately 11 physician employees (“Physician Employees”). In addition to base...more
This opinion addresses a proposed agreement (“Proposed Arrangement”) between a national anatomic pathology laboratory (“Requestor”) and laboratories owned in whole or in part by physicians who may refer (“Referring...more