The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
3/14/2024
/ Bribery ,
Department of Health and Human Services (HHS) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
Federal Health Care Programs (FHCP) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicaid ,
Medicare Fraud ,
OIG ,
Opioid ,
Risk Assessment ,
Sentencing ,
Telemarketing ,
TRICARE ,
Wire Fraud
The Office of Inspector General (OIG) recently issued a new favorable OIG Advisory Opinion, concluding that, although the proposed arrangement (“Proposed Arrangement”) between a Medicare Supplement insurer (“MediGap Plan”)...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
2/7/2024
/ Criminal Convictions ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
False Statements ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Indictments ,
Kickbacks ,
Medicaid ,
Medicaid Drug Rebate Program ,
Medicare ,
Money Laundering ,
OIG ,
Pharmaceutical Industry ,
Physicians ,
Settlement ,
Telemedicine ,
Underpayment
In its January 16, 2023, Enforcement listserv notice, HHS’s Office of Inspector General (“OIG”) recently published Work Plan Updates for January. Although six updates were published, this article only highlights the...more
This favorable OIG opinion relates to a proposed arrangement (“Arrangement”) regarding a one-time voluntary redemption offer to physician partners reaching age 67 to have their partnership units repurchased by the partnership...more
This favorable OIG opinion relates to Requestor who provides consulting services to physician practices and the Requestor’s proposed arrangement (“Proposed Arrangement”) to offer its current physician practice customers...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
1/12/2024
/ Anti-Kickback Statute ,
Compensation ,
Compliance ,
Department of Health and Human Services (HHS) ,
Enforcement ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Healthcare Fraud ,
Kickbacks ,
Medical Devices ,
Medicare Fraud ,
Nursing Homes ,
OIG ,
Popular ,
Risk Assessment ,
Stark Law ,
TRICARE
This favorable OIG opinion concludes that although the proposed arrangement (“Proposed Arrangement”) to subsidize Medicare cost-sharing obligations for Medicare patients in a cardiac clinical trial (“Study”) would constitute...more
The Office of Inspector General (OIG) recently issued two identical favorable OIG Advisory Opinions, concluding that, although the proposed arrangement (“Proposed Arrangement”) between a Medicare Supplement insurer (“MediGap...more
In its December 18, 2023, Enforcement listserv notice, HHS’s Office of Inspector General (“OIG”) published its Work Plan Updates for December. Although six updates were published, this article will only highlight the...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
12/8/2023
/ Anti-Kickback Statute ,
Compliance ,
Criminal Convictions ,
Department of Health and Human Services (HHS) ,
False Billing ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicaid ,
Medicare ,
OIG ,
Pharmaceutical Industry ,
Pharmacies
The Department of Health and Human Services’ (“HHS”) Office of Inspector General (“OIG”) and the Department of Justice (“DOJ”) published their joint Report on the Health Care Fraud and Abuse Control Program for Fiscal Year...more
OIG published its new General Compliance Program Guidance on November 6, 2023. OIG characterizes this as a reference guidance for the health care compliance community and other health care stakeholders. It is identified as...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
11/8/2023
/ Bribery ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Criminal Convictions ,
Damages ,
Department of Health and Human Services (HHS) ,
Department of Veterans Affairs ,
EMTALA ,
Enforcement Actions ,
False Claims Act (FCA) ,
Food and Drug Administration (FDA) ,
Fraud and Abuse ,
Kickbacks ,
Medicare Fraud ,
OIG ,
Penalties ,
Popular ,
Risk Management ,
Settlement ,
TRICARE
This opinion addresses a proposed arrangement (“Proposed Arrangement”) by the manufacturer of cochlear implants (“Requestor”), where the Requestor would provide certain patients who receive one of their implants with a free...more
The safe harbor cap on remuneration for patient engagement and support is adjusted annually based on changes to the consumer price index (“CPI”). 42 C.F.R. §1001.952(hh) protects specified arrangements for patient engagement...more
This opinion addresses a proposed arrangement (“Proposed Arrangement”) between a multi-specialty physician practice (“Requestor”) that employs approximately 11 physician employees (“Physician Employees”). In addition to base...more
This opinion addresses a proposed agreement (“Proposed Arrangement”) between a national anatomic pathology laboratory (“Requestor”) and laboratories owned in whole or in part by physicians who may refer (“Referring...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
10/6/2023
/ Anti-Kickback Statute ,
Civil Monetary Penalty ,
Department of Health and Human Services (HHS) ,
Enforcement ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Healthcare Fraud ,
Kickbacks ,
Medicare ,
Medicare Fraud ,
OIG ,
Popular ,
Self-Disclosure Requirements ,
Telemedicine ,
Wire Fraud
On September 21, 2023, the New York State Office of the Medicaid Inspector General (“OMIG”) posted on its website Compliance Program Requirements Frequently Asked Questions. OMIG intends the FAQs to supplement its Compliance...more
The New York Department of Health (DOH) adopted regulations effective on September 13, 2023, that revised Medicaid Utilization Review for Medicaid fee-for-service benefits. The regulations were initially published on April...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
9/8/2023
/ CARES Act ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Integrity Agreement ,
Deferred Prosecution Agreements ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Economic Injury Disaster Loans ,
Enforcement ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Healthcare Fraud ,
Kickbacks ,
Medicare ,
Medicare Advantage ,
Medicare Fraud ,
OIG ,
Paycheck Protection Program (PPP) ,
Popular ,
Risk Assessment
In its August 15, 2023, Enforcement listserv notice, the U. S. Department of Health and Human Services Office of Inspector General (“OIG”) published its Work Plan Updates for August. This article will highlight three of the...more
8/28/2023
/ Audits ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Grants ,
Healthcare Facilities ,
HRSA ,
Medicare ,
Medicare Part B ,
OIG ,
Opioid ,
Over The Counter Drugs (OTC) ,
Public Health Emergency ,
Substance Abuse ,
Virus Testing ,
Work Plans
On August 21, 2023, the New York State Office of the Medicaid Inspector General (“OMIG”) updated its Medicaid Self-Disclosure Program Requirements. The updated Instructions and Guidelines announce a new “Abbreviated”...more
Harris Beach invites you to register for its 7 Element compliance program series addressing New York’s 2020 and 2022 updates to Medicaid Compliance Program requirements. Starting on August 16th, each live program will be no...more
8/10/2023
/ Anti-Kickback Statute ,
Compliance ,
Department of Health and Human Services (HHS) ,
Enforcement ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medicare Fraud ,
Money Laundering ,
OIG ,
Opioid ,
Risk Management ,
Telemedicine