On December 11, 2024, the U.S. Department of Health & Human Services’ Office of Inspector General (OIG), issued a Special Fraud Alert (Alert) focusing on financial arrangements involving Medicare Advantage (MA) Organizations...more
5/23/2025
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Fraud ,
Government Agencies ,
Health Care Providers ,
Insurance Industry ,
Medicare ,
Medicare Advantage ,
OIG ,
Regulatory Reform
Although most health care lawyers and compliance officers who review and analyze physician compensation understand that fair market value (FMV) is important, the nuances around FMV are sometimes missed....more
8/13/2024
/ Anti-Kickback Statute ,
Audits ,
Chief Compliance Officers ,
Compensation ,
Compliance ,
Corporate Integrity Agreement ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Fair Market Value ,
Healthcare ,
Medical Coding ,
OIG ,
Physician Payments ,
Stark Law ,
Valuation
In connection with the November 2023 Health Care Compliance Association’s (HCCA) Healthcare Enforcement Compliance Conference, and with acknowledgment by the Chief Counsel to the Inspector General, Rob DeConti, of the long...more
11/8/2023
/ Advisory Opinions ,
Anti-Kickback Statute ,
Audits ,
Civil Monetary Penalty ,
Compliance ,
Corporate Integrity Agreement ,
Department of Health and Human Services (HHS) ,
Enforcement ,
Healthcare Fraud ,
OIG ,
Private Equity ,
Risk Assessment ,
Self-Disclosure Requirements
Session #1: State of the Healthcare Industry Effective Compliance Plans and Enforcement Trends -
In their discussion of compliance program effectiveness and enforcement, attorneys Kolarik and Waltz and Ms. Sumner...more
2/23/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Dispute Resolution ,
Enforcement ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Mental Health ,
No Surprises Act (NSA) ,
Physician Fee Schedule ,
Public Health Emergency ,
Risk Assessment
On July 20, 2022, HHS-OIG published a new Special Fraud Alert on arrangements with telemedicine companies, setting forth seven characteristics OIG believes could suggest a given arrangement poses a heighted risk of fraud and...more
In the latest installment of our “Let’s Talk Compliance” series, Foley & Lardner’s Alexis Bortniker and PYA’s Martie Ross answered numerous questions regarding Provider Relief Fund (PRF) reporting requirements. A recording of...more
By letter dated April 13, 2021 (Letter), the Democrat and Republican leadership of the House Committee on Energy and Commerce and its Subcommittee on Health, wrote United States Health and Human Services Secretary, Xavier...more
In the Executive Order on An America-First Healthcare Plan, issued September 24, 2020, President Trump addressed, among other health care issues, the issue of surprise billing (also sometimes characterized as “balance...more
As previously reported in our August 16, 2019 and February 18, 2020 blogs, the Florida Patient Brokering Act (Florida PBA) was amended on July 1, 2019 to change the exception to the Florida PBA from conduct “not prohibited...more
For the second year in a row, Foley & Lardner LLP and PYA hosted a compliance master class on various health-related compliance issues. “Let’s Talk Compliance” is an annual one-day event featuring a panel of presenters that...more
2/11/2020
/ Compliance ,
Covered Entities ,
Cyber Threats ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Health and Human Services (HHS) ,
Due Diligence ,
Electronic Protected Health Information (ePHI) ,
Enforcement Actions ,
Health Care Providers ,
Medical Records ,
Medicare ,
OCR ,
Overpayment ,
Patient Privacy Rights ,
Patient Rights ,
PHI ,
Physicians ,
Ransomware ,
Right-To-Access ,
Risk Assessment
Just in time for the New Year, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued final regulations (Final Regulations) that revised two existing Anti-Kickback Statute safe...more
1/19/2017
/ Advertising ,
Ambulance Providers ,
Anti-Kickback Statute ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Discounts ,
FQHC ,
Free Health-Related Services ,
Health Care Providers ,
Medicare Advantage ,
Medicare Coverage Gap Discount Program ,
OIG ,
Pharmacies ,
Safe Harbors ,
Waivers