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12th Annual Healthcare Fraud & Abuse Review - A Critical Resource for Healthcare Providers

We are pleased to bring you our 12th annual Healthcare Fraud & Abuse Review. Our Review provides comprehensive coverage of the most significant civil and criminal enforcement issues facing healthcare providers. Each year, we...more

HHS-OIG Year in Review 2023

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) is tasked with providing objective oversight to protect the integrity and promote the efficiency of Medicare, Medicaid, and more than...more

Déjà vu? OIG Reiterates Concerns about Providing Free Items or Services to Federal Healthcare Program Beneficiaries

On October 25, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 23-08, in which it refused to approve a proposal by a manufacturer and distributor of hearing...more

OIG Approves Paying Employed Physicians Profits from ASCs Operated by Employer

On October 13, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion 23-07, approving a physician practice’s proposal to pay its physician-employees a portion of the...more

OIG Approves Online Platform's Per-Booking Fees for Medical Appointments and Per-Click Fees for Advertisements

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued Advisory Opinion 23-04, approving the per-booking fees healthcare providers pay a technology company for each new patient who...more

HHS-OIG Year in Review - 2022

The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) continues to offer valuable insights to the healthcare industry as to how best to approach increasingly complex healthcare fraud...more

OIG Offers Stakeholders a New Avenue for Informal Fraud and Abuse Guidance

On March 23, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) announced a new, expanded frequently asked questions (FAQs) process. Although OIG has long maintained FAQs on...more

CMS Tweaks Voluntary Self-Referral Disclosure Protocol, Adds New Form for Group Practice Disclosures

On January 23, the Centers for Medicare & Medicaid Services (CMS) released revisions to its Voluntary Self-Referral Disclosure Protocol (SRDP), an important mechanism through which providers may disclose actual or potential...more

CMS Proposes New Stark Law Exception for Rural Emergency Hospitals

On July 15, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System proposed rule...more

OIG Permits Physician-Employer to Retain Profits from Anesthesia Services Provided by CRNA in Physician Office and ASC

A pain management practice that employs a certified registered nurse anesthetist (CRNA) to provide anesthesia services in both an office location and an ambulatory surgery center (ASC) owned, in part, by the physician-owner...more

CMS Revises Stark Law Indirect Compensation Arrangement Definition, Again

The CY 2022 Medicare Physician Fee Schedule final rule includes further revisions to the definition of the term “indirect compensation arrangement” under the federal physician self-referral prohibition (Stark Law). Less than...more

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