One of the largest settlements, if approved by the Court, is a result of compensation and incentive programs to physicians who were “employed” at Halifax Hospital in Daytona Beach, Florida. The Halifax lawsuit was filed in 2009 by a compliance officer at the hospital who claimed that six oncologists and three neurosurgeons were illegally paid because they received additional payments when they referred and provided more service to hospital patients.

The OIG has been active in recent years in getting its message out. Dan Levinson, in a March 31, 2014 presentation at the HCCA annual meeting, touted the Halifax case as an example of a management flaw—not listening to your compliance officials. He strongly urged that management listen to its compliance staff and mitigate and resolve issues when identified. His presentation was recently posted on the OIG’s YouTube channel and can be accessed here.

Additionally, he preached that compliance plans must be customized as there is no “off-the-shelf” solution to compliance. He further urged that providers use the OIG annual work plan. The work plan provides the government’s blueprint for enforcement on an annual basis and highlights existing and new areas of focus. Of note in this year’s enforcement model according to Levinson, billing and payments for inpatient and outpatient service as well as quality and patient safety are key areas. OIG has begun to look into adverse events in hospitals, nursing facilities and inpatient rehabilitation facilities. The 2014 annual work plan can be accessed here.