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Effective January 1, 2024, the Corporate Transparency Act (“CTA”) requires most businesses, including healthcare businesses, to report certain information regarding beneficial owners and company applicants. Willful failure to report or update beneficial ownership information may result in the imposition of penalties. CTA in a Nutshell The CTA and its implementing regulations seek to The passage of the Protecting Access to Medicare Act (Act) of 2014 ushered in a new era for Medicare laboratory reimbursement rates not seen in three decades. 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. 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. The mission of the Medicaid Fraud Division (MFD) within the Office of the State Comptroller is to prevent, detect, audit and investigate fraud, waste and abuse by New Jersey providers and recipients. As we look forward to the New Jersey Medicaid Fraud Division 2015 work plan, we look back at the agency’s activities in 2014. New York State Social Service Law §363-d and implementing regulations at 18 NYCRR §521 require that certain healthcare providers adopt and implement an effective compliance program and certify their compliance with the law every December. 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. Last year’s passing of the new HIPAA requirements signaled the government’s concern that individually identifiable health information needs stronger protection beyond the borders of the healthcare industry. HIPAA already recognized this need by imposing obligations on covered entities and their business associates in prior versions of the rule. In the latest rule update, however, the US Department of Health and Human Services, among other things, expanded the definition and responsibilities of business associates and now made them directly liable for HIPAA noncompliance. 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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