News & Analysis as of

Audits Dept. of Health and Human Services

New OIG Project Expands Telemedicine Audits to State Medicaid Programs

by Foley & Lardner LLP on

Following on the heels of its plans to review Medicare payments for telehealth services, the federal Office of Inspector General (OIG) at the Department of Health & Human Services (HHS) just announced a new project to review...more

OIG Work Plan – September 2017 Update

by Baker Ober Health Law on

Beginning in June 2017, the OIG began making monthly Work Plan updates. These monthly updates create some practical challenges for health care providers and compliance professionals trying to make operational and compliance...more

Inspector General Audit Could Impact Skilled Nursing Facilities

by Ruder Ware on

Skilled nursing facilities (SNF) may see even more scrutiny from the Centers of Medicare and Medicaid Services (CMS) because of a recent audit conducted by the Office of Inspector General of the U.S. Department of Health and...more

Under the Dome: Inside the Maine State House

by Pierce Atwood LLP on

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Looking Ahead . . . While the First Regular Session of the 128th Legislature has adjourned sine...more

Healthcare Law Update: September 2017

by Holland & Knight LLP on

OIG Advisory Opinions - Manufacturer's Free Replacement of Spoiled Pharmaceutical Products Authorized - On Aug. 25, 2017, the U.S. Department of Health and Human Services' (HHS) Office of Inspector General (OIG)...more

OIG to Audit Medicare Telehealth Services: What You Need to Know

by Foley & Lardner LLP on

For what may be the first time, the Office of Inspector General (OIG) at the Department of Health & Human Services (HHS) recently announced a new project to review Medicare payments for telehealth services. Accordingly,...more

OIG Expands Exclusionary Authority

The Department of Health and Human Services, Office of Inspector General (OIG) published a final rule on January 12, 2017, expanding the OIG’s authority to exclude providers from participation in federal healthcare programs....more

OIG Semiannual Report Highlights FY 2016 Fraud Recoveries, Enforcement Actions

by Reed Smith on

The HHS Office of Inspector General’s (OIG) latest its Semiannual Report to Congress highlights top audits, investigations, and enforcement activities for the period of April 1 to September 30, 2016 and summarizes overall...more

OIG Spring 2016 Semiannual Report to Congress Highlights Enforcement/Investigative Accomplishments

by Reed Smith on

The OIG has issued its Spring 2016 Semiannual Report to Congress, which describes significant enforcement and investigative activities relating to HHS programs during the first half of FY 2016 (October 1, 2015 – March 31,...more

Check Your Inbox: OCR Continues to Verify Entity Contact Information for Phase 2 HIPAA Audits

Covered Entities need to continue to check their inboxes for emails from the HHS Office for Civil Rights (“OCR”) requesting verification of contact information in connection with Phase 2 of the HIPAA Audit Program. OCR...more

Increased Scrutiny of Drug Pricing What Should Pharmaceutical Companies Know

by BakerHostetler on

As U.S. spending on pharmaceuticals continues to rise, reaching $373.9 billion in 2014, government scrutiny of drug pricing practices has increased in response. Early last year, the U.S. Department of Health and Human...more

OIG’s 2016 Work Plan: Mixed Results for 2015 and New Data Mining and Policy Efforts in 2016

by McDermott Will & Emery on

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) annual release of a new Work Plan both summarizes the results achieved last year and highlights new areas for examination in the next....more

Developments in Long-Term Care Q2 2015

by Hodgson Russ LLP on

The following summary highlights key federal court developments and administrative decisions involving skilled nursing facility survey and related issues during the second quarter of 2015....more

OCR Audits to Begin in 2016

Beginning in 2016, the United States Department of Health and Human Services’ Office for Civil Rights (OCR) will conduct another round of audits to gauge compliance with privacy provisions in the Health Insurance Portability...more

HHS’ Selection of Contractor Provides Latest Update on Impending Second Round of HIPAA Audits

by Reed Smith on

On October 27, 2015, a U.S. Department of Health and Human Services (“HHS”) official stated that the agency has hired FCi Federal, a provider of management and professional services to government agencies in Ashburn, VA, to...more

The Bad Debt Moratorium Requires a Flexible Approach to Evaluating "Reasonable Collection Efforts"

by Baker Ober Health Law on

On September 10, 2015, District Judge Randolph D. Moss of the U.S. District Court for the District of Columbia issued an opinion in Mountain States Health Alliance v. Burwell (Mountain States) involving Section 310 of the...more

OIG Hospital Compliance Audits: Is Your Number Up? Are You Ready?

by Baker Donelson on

In its Work Plan for Fiscal Year 2012, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) announced it would begin reviews of Medicare payments to hospitals to determine compliance...more

OIG Reports Insufficient Oversight Of HIPAA Compliance

by King & Spalding on

The HHS Office for Civil Rights (OCR) must improve its oversight and enforcement of patient information privacy and security rules by “covered entities” and their business associates under the Health Information Portability...more

Is Your HIPAA Compliance Program Ready for the FTC?

by Womble Bond Dickinson on

Everyone in healthcare knows that the next round of HIPAA audits is coming. Covered entities and business associates have long been advised to review and update their HIPAA security risk analyses, have business associate...more

OIG report spurs OCR to announce phase 2 audits

On September 29, it was revealed that the HHS Office for Civil Rights (OCR) will commence Phase 2 of its HIPAA audit program in “early 2016.” OCR’s revelation regarding the Phase 2 audits, which had been the subject of...more

Blog: HHS To Launch New HIPAA Audits in Early 2016 in Response to OIG Reports

by Cooley LLP on

The Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) issued two reports yesterday calling for the HHS Office of Civil Rights (OCR) to strengthen its Health Insurance Portability and...more

HHS Issues Proposed 340B Program Omnibus Guidance: Five Things to Watch

by Holland & Knight LLP on

The 340B Drug Pricing Program (340B Program), established by Section 602 of the Veterans Health Care Act of 1992, is administered by the Health Resources and Services Administration (HRSA) of HHS. The 340B Program requires...more

Don’t Wait for It; Recent HIPAA Enforcement Action Signal More to Come in Phase 2 Audits

by Orrick - Trust Anchor on

Officials at the U.S. Department of Health and Human Services Office of Civil Rights (HHS OCR) have recently selected a vendor to conduct the second wave of HIPAA audits. These so-called “Phase 2 Audits” are set to commence...more

$750,000 HIPAA Settlement Reinforces Need to Be Proactive

by Epstein Becker & Green on

As the Department of Health and Human Services’ (“HHS”) Office of Civil Rights (“OCR”) proceeds with its second round of HIPAA audits, this time covering business associates as well as covered entities, a recent settlement...more

340B Guidance: Eight Key Points Covered Entities Should Consider

by BakerHostetler on

On August 27, 2015, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), released the 340B Drug Pricing Program Omnibus Guidance (Guidance). Referred to...more

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