News & Analysis as of

Office of the Inspector General Hospitals

Gainsharing Guidance: Clarification on Cost-Savings Arrangements Between Hospitals and Physicians

by Polsinelli on

The Office of Inspector General of the U.S. Department of Health and Human Services (OIG) recently posted its first advisory opinion interpreting a gainsharing arrangement – that is, a financial relationship under which...more

OIG Issues Favorable Advisory Opinion Addressing Gainsharing CMP Arrangement

by Dorsey & Whitney LLP on

On January 5, 2018, the Office of the Inspector General of the United States Department of Health and Human Services (“OIG”) released a favorable Advisory Opinion 17-09 that addresses Section 1128A(b)(1) of the Social...more

HHS-OIG Issues Favorable Opinion on Gainsharing Arrangement

by McGuireWoods LLP on

On Jan. 5, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) published a favorable advisory opinion regarding a nonprofit acute care hospital’s proposed shared savings program involving...more

Pushing “PAUSE” on the 340B Program: The New Bi-Partisan Bill that Could Reshape the 340B Program

by McDermott Will & Emery on

In late December 2017, Republican Rep. Larry Bucshon (with bi-partisan support) introduced the “340B Protecting Access for the Underserved and Safety-net Entities Act” (340B PAUSE Act), legislation that would implement a...more

OIG Issues Favorable Gainsharing Advisory Opinion

by King & Spalding on

On December 29, 2017, OIG issued a favorable advisory opinion interpreting the application of the gainsharing civil monetary penalty provision (Gainsharing CMP) and the Anti-Kickback Statute in connection with a proposed...more

Legislation, Lawsuit Cloud Future of 340B Program Payment Rate Reductions

by Jones Day on

The Situation: A Final Rule published by the Centers for Medicare & Medicaid Services carries a provision that reduces reimbursement for most 340B Program drugs dispensed by disproportionate share hospitals and rural referral...more

OIG November 2017 Work Plan Update

by Baker Ober Health Law on

The OIG added four items to its Work Plan with the November 2017 update, as listed on the chart below. Interestingly, three of the four new items relate to Medicaid. Hot topics include prescriptions for extreme amounts of...more

OIG Advisory Opinion 17-06: Another Medigap/PHO Arrangement Approved

by Baker Ober Health Law on

Advisory Opinion 17-06 joins a long list of opinions approving arrangements between a Medicare Supplemental Health Insurance (Medigap) insurer and a preferred hospital organization (PHO). While this advisory opinion does not...more

Hospitals Will Need Psychiatrists And Mental Health Professionals To Satisfy EMTALA

by Cozen O'Connor on

Hospitals that have emergency departments should call upon their “available resources” to screen and stabilize patients with mental health emergencies as required by the Emergency Medical Treatment and Labor Act (“EMTALA”)...more

OIG Finds Continued Procedural Errors in Hospital Outlier Payment Reconciliations

by Baker Ober Health Law on

The U.S. Department of Health and Human Services, Office of Inspector General (OIG) recently released a report concluding that there are vulnerabilities in the process of reconciling Medicare hospital outlier payments....more

OIG Finds Acute Care Hospitals Improperly Billed for Outpatient Services Provided to Inpatients of Other Hospitals

by Baker Ober Health Law on

Acute care hospitals that provide Medicare outpatient services to inpatients of other hospitals should be billing and collecting payment from the other inpatient hospitals and not from Medicare....more

OIG Report Finds Medicare Inappropriately Paid Hospitals for Certain Outpatient Services

by King & Spalding on

Last week, HHS OIG released a report finding that Medicare inappropriately paid acute-care hospitals for outpatient services provided to beneficiaries who were inpatients of other facilities, such as long-term care hospitals,...more

In Targeting Outlier Payment Reconciliation, OIG Calls for an Aggressive Reading of CMS Reopening Regulations

by King & Spalding on

The HHS OIG recently published a report detailing CMS’s and Medicare Administrative Contractor’s (“MACs’”) ongoing issues in the outlier payment reconciliation process. A previous 2012 review identified 465 cost reports that...more

OIG Approves (Yet) Another Medigap/PHO Arrangement in Advisory Opinion 17-04

by Baker Ober Health Law on

With Advisory Opinion 17-04, issued August 24, 2017, the U.S. Department of Health and Human Services, Office of Inspector General (OIG) adds to the ever-growing number of favorable advisory opinions regarding an agreement...more

OIG Advisory Opinion Allows Waiver of Cost Sharing in Research Studies

by Polsinelli on

Recently, the U.S. Department of Health and Human Services, Office of Inspector General (“OIG”) issued an Advisory Opinion (17-02) that allows for waivers or reductions of cost-sharing amounts owed by financially needy...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

Blog: OIG Releases August Work Plan Items

by Cooley LLP on

As we recently announced, the Office of Inspector General (OIG) is updating its Work Plan monthly rather than its previous twice-yearly publications. The August updates released this week include 4 new Work Plan items:...more

Settlement Creates Uncertainty in Determining EMTALA Obligations

by King & Spalding on

On June 23, 2017, a South Carolina-based hospital system, AnMed Health, agreed to pay $1,295,000 to settle allegations that it violated the Emergency Medical Treatment and Labor Act (EMTALA). The HHS OIG alleged AnMed held...more

Hospital and its Clinic Agree to $34 Million Settlement to False Claims Act Allegation that Compensation to Oncologists Violated...

Last week, the Department of Justice (DOJ) entered into a $34 million settlement with Mercy Hospital Springfield (“Hospital”) of Springfield, Missouri, and its affiliate Mercy Clinic (“Clinic”). The settlement resolves an...more

CMS Gamed System to Identify Hospitals Gaming System?

by Faegre Baker Daniels on

You can’t make this stuff up. When CMS conducted a study to identify hospitals that game the quality data reporting system, it used an approach that made the data reporting look better than it actually was. That bottom line...more

The OIG 2017 Work Plan Includes Focus on Hospitals - Corridors Newsletter April 2017

by Poyner Spruill LLP on

The U.S. Department of Health and Human Services (DHHS) Office of Inspector General (OIG) has issued its Work Plan for Fiscal Year 2017. The annual Work Plan provides a summary of new, revised, and continuing reviews for DHHS...more

New Safe Harbor Permits Some Free Transportation to Patients

by Ruder Ware on

A new safe harbor was recently issued by the Health and Human Services (HHS) Office of Inspector General (OIG) that permits eligible health care providers to offer free or discounted transportation to established patients....more

Healthcare Law Update: March 2017

by Holland & Knight LLP on

Enforcement - OIG Issues Advisory Opinion Allowing Free or Reduced-Cost Lodging and Meals - On March 3, 2017, the U.S. Department of Health and Human Services' (HHS) Office of Inspector General (OIG) issued...more

OIG Issues Favorable Advisory Opinion Relating to Free Hotel Lodging and Cafeteria Meals for Qualifying Patients

by Arnall Golden Gregory LLP on

On March 3, 2017, the U.S. Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 17-01. The Opinion relates to a request by an academic medical center (the “Requestor”) consisting...more

Pharmaceutical Manufacturers and Healthcare Leaders cite Fraud and Abuse Laws as Obstacle to Value-Based Arrangements

As the healthcare industry moves towards value-based purchasing, pay-for-performance, and other payment reform models, industry leaders have identified federal fraud and abuse laws as a barrier to full implementation of such...more

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