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OIG Advisory Opinion: Free Hearing Aids from Cochlear Implant Maker Could Violate Fraud and Abuse Laws

The US Department of Health and Human Services Office of Inspector General (OIG) posted on October 25, 2023 Advisory Opinion No. 23-08, in which OIG rejected a proposed arrangement from a cochlear implant device manufacturer...more

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

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

OIG Unveils New General Compliance Program Guidance, First Major Update Since 2008

The US Department of Health and Human Services Office of Inspector General (OIG) released its new General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG is designed to serve as a reference guide for the...more

OIG Approves Per-Click Marketing Arrangement Involving Online Healthcare Directory

The US Department of Health and Human Services Office of Inspector General (OIG) recently released Advisory Opinion No. 23-04, which found that fraud and abuse risks were sufficiently low in light of certain safeguards to...more

Hospice General Inpatient Services (GIP): New OIG Audit Alert

The HHS Office of Inspector General (OIG) announced on June 15, 2023 that it plans to initiate a new audit of Medicare payments for hospice general inpatient (GIP) services, focused on hospice GIP services furnished to...more

OIG Overhauls Compliance Program Guidance Process

The US Department of Health and Human Services Office of Inspector General (OIG) announced on April 25 that it would be updating its Compliance Program Guidances (CPGs)....more

Fraud Scheme Alert for Healthcare Providers: Bogus Nursing Degrees Sold to Thousands

The US Department of Justice and Department of Health and Human Services Office of Inspector General have identified a wire fraud scheme to sell false and fraudulent nursing degree diplomas and transcripts. Coined as...more

OIG Hospice Audits of Provider Relief Fund Use Have Arrived

The HHS Office of Inspector General (OIG) has, for the last several years, been actively auditing hospices regarding their Medicare regulatory and billing compliance, with a national hospice audit in the works. Recently, OIG...more

OIG Planning Nationwide Audit of Hospice Eligibility – What You Should Know

The HHS Office of Inspector General (OIG) recently announced its Office of Audit Services plans to conduct a nationwide review of hospice eligibility, focusing on those Medicare hospice beneficiaries who haven't had an...more

MA Audit: Hospices Unaware of Dual Eligibles Medicaid Filing Rule, Causing Potential Overpayments

The US Department of Health and Human Services, Office of Inspector General (OIG) recently transmitted a memorandum to the Center for Medicaid and CHIP Services detailing the findings of the Massachusetts state auditor's...more

CMS Relaunches Hospice TPE Audits with Long-Stay General Inpatient Reviews

The Centers for Medicare and Medicaid Services (CMS) announced that it had restarted the Targeted Probe and Educate (TPE) audit process, effective September 1, 2021. More recently, the Medicare Administrative Contractors for...more

HHS Makes More Provider Relief Funds Available, Offers 60-Day Grace Period for First Reporting Deadline

The US Department of Health and Human Services (HHS) recently announced that it will make $25.5 billion available in new COVID-19 relief funds to providers through the Health Resources and Services Administration (HRSA). To...more

July Fast Break Recap: Fourth Circuit AKS Case Enforcement Analysis

We hope you were able to join us for our July Fast Break on the US Court of Appeals for the Fourth Circuit's recently affirmed $114 million judgment in United States v. Mallory. If not, you missed a great session, featuring...more

Hospice: Consolidated Appropriations Act Revamps Medicare Survey and Certification Process

Modifications also include public disclosure of accreditation organization survey information and intermediate civil penalty remedies for noncompliance. The Consolidated Appropriations Act, 2021 (Pub. L. 116-260), signed into...more

Recent Anti-Kickback Safe Harbor Revisions: What Hospices Should Know

The US Department of Health and Human Services Office of Inspector General (OIG) recently issued important updates to its Anti-Kickback Statute (AKS) safe harbor rules that provide additional legal protections and...more

OIG Embraces Broader Anti-Kickback Statute Safe Harbor Protection for Warranties

The US Department of Health and Human Services’ Office of Inspector General updated the warranty safe harbor to account for bundled product and service warranties to reflect realities of healthcare product sales, but rejects...more

Recent Government Hospice Reports: Unfavorable Findings Continue

The government watchdog agencies continue to focus their attention on Medicare oversight of hospice providers, with two recent reports from the US Government Accountability Office (GAO) and the HHS Office of Inspector General...more

OIG and CMS Coordinate Seismic Change to Fraud and Abuse Laws—What It Means for the Health Industry

Highlighting the US Department of Health and Human Services’ (HHS) efforts to transform the US healthcare system to a value-based model, the Office of the Inspector General (OIG) and the Centers for Medicare and Medicaid...more

OIG Recommends Increased Oversight and Reporting Requirements for Hospice

In keeping with its recent recommendations to CMS, the Office of Inspector General for the US Department of Health and Human Services (OIG) is recommending increased oversight and compliance reporting requirements for...more

OIG Report on Hospice Vulnerabilities: Recommendations Receive Lukewarm Support from CMS

The Office of Inspector General Portfolio Report is a rehash of the watchdog agency’s 2006–2016 findings on quality of care concerns and program integrity issues. The report, which garnered some critical press attention for...more

Retail Pharmacy: OIG Signals It’s Okay to Reward Again

OIG Advisory Opinion paves the way for expanded retailer reward programs. The US Department of Health and Human Services Office of Inspector General (OIG) issued an advisory opinion on September 7 that provides important...more

OIG Issues Critical Medical Review Report of Hospice GIP

The report shows significant lapses in 2012 GIP service claims and recommends that CMS implement additional oversight and enforcement options....more

OIG Recommends Greater Scrutiny for Hospice Services in ALFs

The OIG’s recently released study examining Medicare hospice claims from 2007 to 2012 calls for targeted reviews of hospices that receive a high proportion of their payments for care in assisted living facilities....more

CMS Final Rule Adds More Arrows but also Demonstrates Restraint

CMS reconsiders $10 million bounties for reporting of regulatory violations. On December 5, the Centers for Medicare & Medicaid Services (CMS) finalized a rule (the Final Rule) that expands its program integrity and...more

OIG Proposes Rules on Free Transportation, Hospital Gainsharing, and Other Access to Care Arrangements

The proposed rule to give providers more protections to promote beneficiary access to care solicits significant industry input. On October 2, the Department of Health and Human Services (HHS) Office of Inspector...more

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