News & Analysis as of

Physicians Department of Health and Human Services (HHS) Office of the Inspector General

Husch Blackwell LLP

Hospice Insights Podcast - A Refresh: What’s New in the New OIG General Compliance Program Guidance

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Compliance gets a dust off with the new General Compliance Program Guidance released by the federal Office of the Inspector General (OIG) in November 2023. While there is a lot to digest, Husch Blackwell’s Josi Wergin and...more

Maynard Nexsen

OIG OKs Physician Consultant Gift Card Arrangement

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On January 3, 2024, the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) published OIG Advisory Opinion No. 23-15 (the “Opinion”), which addresses a request from a consulting company (the...more

Hendershot Cowart P.C.

Doctors: Don’t Fall Victim To Telemedicine Fraud Schemes

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Telemedicine companies are supposed to facilitate medically necessary services to beneficiaries over the telephone via licensed medical professionals. In reality, however, many of these “telemedicine companies” are...more

Health Care Compliance Association (HCCA)

In Biggest Stark-Based FCA Settlement Ever, Indiana Hospital Pays $345M, Has Unusual CIA

Community Health Network (CHN) in Indiana has agreed to pay $345 million to settle false claims allegations that it paid over-the-top salaries to hundreds of physicians and rewarded them for their referrals in violation of...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - March 1st, St. Louis, MO

Looking for compliance education and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance education on a wide variety of current and emerging topics...more

Harris Beach PLLC

OIG January 2024 Enforcement Summary

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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

Morgan Lewis - Health Law Scan

OIG Approves Consultant’s Provision of Gift Cards to Physician Practices

The US Department of Health and Human Services Office of Inspector General (OIG) published favorable Advisory Opinion No. 23-15 on January 3, which concluded that a consultant’s proposal to provide gift cards to existing...more

Maynard Nexsen

2024 Compliance Guidance from the OIG: Part I

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On November 6, 2023, for the first time since 2008, the US Department of Health and Human Services (“HHS”) Office of the Inspector General (“OIG”) issued comprehensive “General Compliance Program Guidance” (“GCPG”) for all...more

Harris Beach PLLC

HHS OIG Work Plan – December Update – Audits for Medicare Emergency Codes

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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

Bricker Graydon LLP

A Long-Awaited Change: OIG Updates its Compliance Program Guidances

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From 1998-2008, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) published compliance program guidelines for various industries in the Federal Register....more

Jones Day

HHS-OIG Issues Long-Anticipated General Compliance Program Guidance for All Health Care Stakeholders

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In Short - The Situation: On November 6, 2023, the Office of Inspector General ("OIG") of the U.S. Department of Health and Human Services ("HHS") released its "General Compliance Program Guidance" ("GCPG"). The GCPG...more

Venable LLP

OIG Provides Guidance on Physician Bonus Compensation

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On October 13, 2023, the Department of Health and Human Services Office of Inspector General (the OIG) released an advisory opinion regarding a multi-specialty physician practice's (the Practice) proposed plan to pay bonuses...more

Morgan Lewis

OIG Releases New ‘One-Stop Shop’ General Compliance Program Guidance

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The US Department of Health and Human Services Office of Inspector General (OIG) released on November 6 its General Compliance Program Guidance (GCPG), a helpful new resource for the healthcare industry that consolidates...more

Katten Muchin Rosenman LLP

OIG Issues Favorable Advisory Opinion for Certain Physician Employee Bonuses

On October 13, 2023, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) posted Advisory Opinion No. 23-07. In this opinion, the OIG responded favorably to a proposed arrangement whereby...more

Saul Ewing LLP

Trick or Treat: HHS OIG Approves Employed Physician Bonus Proposal That Includes ASC Referrals

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In October 2023, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) published Advisory Opinion 23-07 and approved a plan by a multi-specialty physician practice to pay its employed...more

Stevens & Lee

OIG Issues Favorable Opinion Concerning Bonus Payments to Employed Physicians

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The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently considered the question whether an employed physician can be paid bonus compensation relating to procedures performed by the...more

McGuireWoods LLP

HHS Advisory Opinion Approves Profit-Based Bonus Plan for Bona Fide Physician Employees

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On Oct. 13, 2023, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion 23-07 approving a multispecialty physician practice’s proposal to pay bonuses to each of its...more

McDermott Will & Emery

OIG Pathology Lab: Don't Pay for Services You Don't Need

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In September, the US Department of Health and Human Services Office of Inspector General (OIG) issued an unfavorable advisory opinion to a pathology laboratory concerning a proposed services arrangement with referring...more

Holland & Knight LLP

OIG Looks at How Employed Physicians Bonuses Are Paid from ASC Profits

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The U.S. Department of Health & Human Services Office of the Inspector General (OIG) on Oct. 13, 2023, posted Advisory Opinion No. 23-07 detailing a favorable response to a proposal by a Requestor to pay bonuses to its...more

Bass, Berry & Sims PLC

OIG Approves Paying Employed Physicians Profits from ASCs Operated by Employer

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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

Mintz - Health Care Viewpoints

OIG Issues Advisory Opinion Nixing Purchased Services Arrangement Between Certain Anatomic Pathology Laboratories

Last week the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) issued Advisory Opinion 23-06 (AO), which advised that a proposed arrangement between certain laboratories for the purchase...more

Holland & Knight LLP

OIG Says Proposed Neurological Monitoring Arrangement Creates Kickback Risk

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The U.S. Department of Health and Human Services Office of Inspector General (OIG) issued an unfavorable Advisory Opinion on Aug. 15, 2023, involving an intraoperative neuromonitoring (IONM) services arrangement. The Advisory...more

Stevens & Lee

OIG Says Proposed Surgery Monitoring Arrangement May Violate Kickback Statute

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On August 18, the Office of Inspector General in the Department of Health and Human Services (“OIG”) issued Advisory Opinion 23-05 in which it concluded that a proposed arrangement involving the formation of a company...more

Harris Beach PLLC

Office of Inspector Warns Against Proposed Surgeon-owned Turnkey Intraoperative Neuromonitoring Business

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In a rarely seen “unfavorable” advisory opinion, the United States Department of Health and Human Services Office of Inspector General (“OIG”) recently warned that an entity’s (“Requestor”) proposal to assist surgeons in...more

Health Care Compliance Association (HCCA)

[Event] 2023 Healthcare Enforcement Compliance Conference - November 5th - 7th, Washington, DC

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us at HCCA’s Annual Healthcare Enforcement Compliance Conference to...more

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