Board members for organizations of all sizes need to be familiar with the OIG’s recent publication of Practical Guidance for Health Care Governing Boards on Compliance Oversight. This informative guide is intended to assist the Board member of any health care organization fulfil compliance obligations with the myriad of health care laws and regulations. Although … Continue Reading
On February 7, 2014, the Centers for Medicare and Medicaid Services (CMS) issued a memorandum that adds to the growing library of federal guidance on the permissibility of and limitations for health care providers and other entities paying the premiums of patients covered by qualified health plans (QHPs) in the health insurance exchanges or marketplaces. … Continue Reading
Health care fraud accounts for billions of the US health expenditure each year. This week HHS published a study addressing possible deficiencies in CMS’ capability to address fraud vulnerabilities and ensure the integrity of electronic health records (“EHR”) systems which CMS and its contractors use to pay Medicare claims. Concerns about whether CMS’ oversight and … Continue Reading
On December 27, 2013, the Centers for Medicare and Medicaid Services (“CMS”) and the Office of Inspector General of the Department of Health and Human Services (“OIG”) published final rules (“Final Rules”) regarding the electronic health records (“EHR”) donations Stark Law Exception (42 C.F.R. 411.357(w)) and Anti-Kickback Statute Safe Harbor (“AKS Safe Harbor”) (42 C.F.R. … Continue Reading
Recently, many stakeholders in the healthcare industry have expressed interest in implementing programs that provide funding to help patients with insurance premium payments. Until last week, it was unclear whether any type of premium assistance programs would be permissible under federal law. Finally, in Office of Inspector General (OIG) Advisory Opinion 13-19 posted on December … Continue Reading
In response to a recently released Office of Inspector General (“OIG”) report that concluded CMS is overpaying many Critical Access Hospitals (CAHs), CMS pledged to reassess all CAHs’ certification. The report asserts that CMS could realize substantial savings by decertifying non-compliant CAHs because nearly two-thirds of CAHs would not meet the location requirements if required … Continue Reading
OIG Issues Special Fraud Alert: Physician-Owned Distributorships (PODs) On March 26, 2013 the Department of Health and Human Services, Office of Inspector General (OIG) issued a Special Fraud Alert: Physician-Owned Entities (Alert). The Alert focuses on the specific attributes and practices of “physician-owned entities that derive revenue from selling, or arranging for the sale of, … Continue Reading
As part of its Work Plan for Fiscal Year 2013, the Office of Inspector General (“OIG”) plans to focus on the following current and new issues in the Medicaid program: prescription drugs; home, community, and personal care services; equipment and supplies; state management and oversight; the Children’s Health Insurance Program; Medicaid data systems, controls, and … Continue Reading
Concurrently with the release of the final rule for accountable care organizations participating in the Medicare Shared Savings Program (“MSSP”), the Centers for Medicare and Medicaid Services (“CMS”) and the Department of Health and Human Services, Office of Inspector General (“OIG”) released an interim final rule with a comment period addressing waivers of certain fraud … Continue Reading
