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 its November 2023 Proposed Rule and in its recently issued Final Rule that will be published in the Federal Register later this month, the Centers for Medicare & Medicaid Services (CMS) addressed concerns related to agent...more
4/23/2024
/ Brokers ,
Centers for Medicare & Medicaid Services (CMS) ,
Compensation ,
Contract Renewal ,
Enrollment ,
Fraud and Abuse ,
Health Insurance ,
Medicare Advantage ,
Medicare Part D ,
OIG ,
Proposed Rules ,
Public Health Insurance Marketplace ,
Risk Management
Editor’s Note: PYA and Foley & Lardner hosted the 6th Annual “Let’s Talk Compliance” two-day Virtual Conference on January 18 and 19, 2024. Panelists included Foley & Lardner attorneys and PYA experts. The event was hosted by...more
2/19/2024
/ Artificial Intelligence ,
Collaboration ,
Compensation ,
Compliance ,
Ethics ,
Fair Market Value ,
Governance Standards ,
Health and Safety ,
Health Technology ,
Healthcare ,
Internal Controls ,
Machine Learning ,
OIG ,
Physicians ,
Privacy Laws ,
Regulatory Requirements ,
Value-Based Payments
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
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
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
This is an uncomfortable summer for health care providers in Florida! The legal landscape changed dramatically over the 4th of July holiday. Buried in Florida’s HB 369 regarding substance abuse services was a dramatic...more
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