OIG’s Strengthens its Exclusion Authorities

The Office of Inspector General (OIG) recently published a final rule that implements OIG’s expanded statutory exclusion authority. The final rule included a number of provisions that impact providers and suppliers.

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Medicaid Enrollment For Providers Got Tougher, But Many States Lack Enhanced Screening

The Affordable Care Act (ACA) heralded a new era of provider enrollment screenings not only in the Medicare program but also in States’ Medicaid programs. A series of new Office of Inspector General (OIG) reports reviewed the effectiveness of the States’ implementation of the new screening requirements in the Medicaid programs and found areas in need of improvement.

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Medicare Enrollment Screening Tools Reviewed By OIG

The Centers for Medicare & Medicaid Services (CMS) views the enrollment process as an important gatekeeping tool for preventing fraud, waste and abuse. The passage of the Affordable Care Act (ACA) enhanced the ability of CMS to further this goal. Recently, the Office of the Inspector General (OIG) published a report analyzing the effectiveness of certain enhanced provider enrollment screenings.

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OIG 2016 Workplan: Is It Time To Check Your Compliance?

Every year the Office of the Inspector General (OIG) issues a workplan that identifies the agency’s planned audit activities for the upcoming year. The workplan offers valuable information for healthcare entities by providing them with an opportunity to conduct appropriate risk assessments, and, where indicated, to modify the entity’s compliance program.

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Chiropractic Billings Under Government Scrutiny Again

Consistently over the years the Office of Inspector General (OIG) has targeted chiropractic services for audits. In fact, chiropractic services appear annually on the OIG’s workplan agenda. In September 2015, the OIG issued a report recommending that the Centers for Medicare & Medicaid Services’ (CMS) establish better controls and measures to prevent questionable payments, collect overpayments based on inappropriately paid claims and ensure that claims are paid only for Medicare-covered diagnoses.

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Medicaid Audit: Lessons for NJ Personal Care Agencies

The Office of Inspector General (OIG) recently audited New Jersey’s personal care program and found certain deficiencies as a result of noncompliance with Federal and State requirements by some personal care agencies. Based on the audit result, the OIG asked the State to return $32,236,308 in Federal Medicaid reimbursement for personal care services that the OIG claimed did not meet Federal and State requirements.

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OIG Finds OCR and Billing for Ambulance Services Needs Improvement

In a series of recent reports, the Office of Inspector General (OIG) noted a number of deficiencies and made a number of recommendations to improve and strengthen oversight of the HIPAA Privacy Standards and reduce the amount of inappropriate transportation billing.

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A Tricky Balance for Online Coupons Advertising Medical Services

Recent guidance from the New York State Office of the Professions (OP) suggests that the agency did not entirely reject Internet coupons or vouchers that many refer to as “Groupons.” The OP did, however, affirm concerns previously expressed here that offering coupons for medical services requires careful consideration.

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OIG Says Lab Can’t Provide Free Services

In a recent advisory opinion, the Office of Inspector General (OIG) nixed a proposed arrangement whereby a multi-regional laboratory (Lab) sought to provide free services to out-of-network patients in exchange for exclusivity in referrals from the physicians.

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Warnings to Pharmacies About Accepting Coupons and Special Business Arrangements

The Office of Inspector General (OIG) within the U.S. Department of Health and Human Services recently issued two reports reminding providers and suppliers of the importance of carefully vetting their business arrangements before signing on the dotted lines.

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OIG’s New Fraud Alert: Improper Payments From Labs to Docs

The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) released a special fraud alert (Alert) in June concerning suspect arrangements between laboratories and physicians that raise Anti-Kickback statute (AKS) concerns.

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HHS OIG Releases 2014 Work Plan

Every year the U.S. Department of Health and Human Services Office of the Inspector General (OIG) publishes a work plan that provides industry stakeholders with insight as to the OIG’s new and ongoing auditing and investigative activities in the upcoming year.

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OIG Nixes Proposed Physician Lab Arrangement

A new advisory opinion from the Office of the Inspector General (OIG) of the Department of Health and Human Services nixed a proposed arrangement between an independent clinical laboratory and physician groups highlighting the intense scrutiny of lab-physician agreements.

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Devastating Impact of Provider Exclusion – Special Bulletin

The government’s authority to exclude practitioners from participation in Federal health care programs has expanded dramatically since program exclusions upon conviction first began back in 1977. In an attempt to address industry questions about the scope of exclusion in today’s regulatory climate, the Office of the Inspector General (OIG) issued an updated Special Advisory bulletin this past May.

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More Inspections and Scrutiny Under OIG’s 2013 Workplan

Each year the U.S. Department of Health and Human Services Office of the Inspector General (OIG) produces a work plan that outlines the agency’s focus for the upcoming year. With a staff of over 1,700 professionals, the OIG conducts investigations, audits, and, among other projects, enters and monitors corporate integrity agreements. Below we discuss some of the highlights from the OIG 2013 Work Plan.

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OIG Recoveries and Exclusions Rise in 2011

Recently, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) calculated the savings its programs brought to the Federal government in 2011. The statistics, which reveal recoveries in the billions, serve as a sobering reminder to providers of the increasing interest by the government in ensuring that providers are complying with the healthcare laws and regulations.

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Impact of Provider Exclusion from Medicare on Employers

In our prior articles, we discussed the far reaching impact of an Office of Inspector General (OIG) exclusion from the Medicare Program on providers and suppliers. Exclusion from the Medicare Program also impacts employers and we address some of those ramifications below.

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Far Reaching Impact of Medicare Exclusion

In our prior articles, we looked at the basis for Medicare exclusion and how the Office of the Inspector General’s (OIG) powers to exclude providers has been recently enhanced by the passage of the Affordable Care Act. In this article we focus on the sweeping impact that exclusion has on providers and suppliers.

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Basis for Medicare Exclusion

The Office of the Inspector General (OIG) within the Department of Health and Human Services (HHS) has broad authority to take measures such as excluding providers and suppliers from participating in the Medicare Program in order to protect the program and beneficiaries. There are a number of reasons why exclusions may be imposed and we summarize them below.

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OIG Discusses Groupon-type Advertising Arrangement

Groupon-type advertising is all the rage now but serious legal, ethical and contractual questions exist for medical and dental practices that need to be examined prior to entering into such arrangements. We have previously addressed this evolving issue in several articles on this website by evaluating some of the implications such arrangements have for providers. One of our articles was just published in the American Association of Oral and Maxillofacial Surgeons’ (AAOMS) bimonthly publication, Practice Management Notes. We are pleased to bring it to you here.

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