Christine Clements

Christine Clements

Sheppard Mullin Richter & Hampton LLP

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Special Fraud Alert: Suspect Payments in Marketing Arrangements Related to Medicare Advantage and Providers

Yesterday, the OIG released a Special Fraud Alert related to: (1) marketing arrangements between Medicare Advantage Organizations (“MAOs”) and health care professionals (“HCPs”), and (2) arrangements between HCPs and MA plan...more

12/13/2024  /  Health Care Providers , Healthcare Fraud , Medicare , Medicare Advantage , Medicare Advantage Organizations (MAOs) , OIG

CMS Issues Long-Awaiting Medicare Advantage RADV Final Rule

On January 30, 2023, the Centers for Medicare & Medicaid Services (“CMS”) released the long-delayed final rule on risk adjustment data validation (“RADV”) audits of Medicare Advantage (“MA”) organizations (the “Final...more

2/2/2023  /  Audits , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Final Rules , Medicare , Medicare Advantage , Medicare Advantage Organizations (MAOs) , OIG , Overpayment Recovery Time Limits

HHS OIG Report On Prior Authorizations Under Medicare Advantage

Last month, the U.S. Department of Health and Human Services Office of Inspector (“OIG”) released a report that studied prior authorization denials and payment denials by Medicare Advantage Organizations (“MAOs”) (the...more

5/5/2022  /  Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Medicare , Medicare Advantage , Medicare Advantage Organizations (MAOs) , OIG

HHS OIG Signs Off on Substance Use Recovery Incentive Program

On March 2, 2022, the Department of Health and Human Services (“HHS”) Office of the Inspector General (the “OIG”) issued a new advisory opinion (“AO 22-04”) related to a program through which the Requestor would provide...more

3/25/2022  /  Advisory Opinions , Anti-Kickback Statute , Civil Monetary Penalty , Crisis Management , Department of Health and Human Services (HHS) , Drug Treatment , OIG , Substance Abuse

HHS OIG Issues Report Critical of Medicare Advantage Risk Adjustment Practices

Earlier this month, the U.S. Department of Health and Human Services Office of the Inspector General (the “OIG”) released a report highlighting concerns about the extent to which Medicare Advantage Organizations (“MAOs”) are...more

9/25/2020  /  Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , HRA , Medicaid , Medicare , Medicare Advantage , Medicare Advantage Organizations (MAOs) , OIG , Payment Systems , Risk Assessment

How Broad is the Managed Care Safe Harbor?

In Advisory Opinion No. 18-11, the Department of Health and Human Services Office of the Inspector General (the “OIG”) addressed a Medicaid managed care organization’s (“MCO”) proposal to pay its contracted providers and...more

10/29/2018  /  Advisory Opinions , Anti-Kickback Statute , Beneficiaries , Department of Health and Human Services (HHS) , Health Care Providers , Health Clinics , Hospitals , Incentives , Managed Care Contracts , MCOs , Medicaid , OIG , Safe Harbors
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