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Centers for Medicare & Medicaid Services (CMS) Self-Disclosure Requirements

WilmerHale

DOJ Health Care Fraud Unit Announces First Enforcement Action Under Updated Corporate Enforcement Policy

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The U.S. Department of Justice (“DOJ”) Criminal Division and the U.S. Attorney’s Office for the Western District of North Carolina recently announced the first non-prosecution agreement (“NPA”) coming out of DOJ’s Health Care...more

Hendershot Cowart P.C.

Texas Healthcare Providers Paid $21.3 Million to Resolve Stark Law Violations in 2024

Hendershot Cowart P.C. on

Healthcare fraud enforcement continues to be a top priority for federal authorities, with Stark Law violations remaining under particular scrutiny. The complex nature of physician self-referral regulations, combined with...more

Whiteford

Preparing For 2025 Stark Enforcement Regarding Compensation and Productivity Bonuses

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In 2024, Stark enforcement remains a critical focus for healthcare providers and regulatory bodies, with a continued focus on excessive compensation and productivity bonuses. Compliance with Stark Law is essential to avoid...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - November 1st, Scottsdale, AZ

Looking for compliance education and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance education on a wide variety of current and emerging topics...more

Foley & Lardner LLP

“Let’s Talk Compliance”: OIG’s General Compliance Program Guidance: How to Refresh Compliance Programs

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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

Sheppard Mullin Richter & Hampton LLP

Should my Company Self-Disclose Major Fraud? The Answer is Now Clear

After conducting a thorough and privileged internal investigation, it becomes evident that your Company has overcharged the government over $50 million, and that the fraud was directed by a high-level manager. What do you do...more

McGuireWoods LLP

CMS Settles Record Number of Stark Self-Disclosures

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The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2021 and 2022 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law...more

Health Care Compliance Association (HCCA)

[Event] 2023 Healthcare Enforcement Compliance Conference - November 5th - 7th, Washington, DC

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us at HCCA’s Annual Healthcare Enforcement Compliance Conference to...more

Hendershot Cowart P.C.

A Provider’s Guide to OIG's Self-Disclosure Protocol

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The OIG offers providers an opportunity to self-report certain violations under its Health Care Fraud Self-Disclosure Protocol. If you uncover a violation of federal healthcare laws or requirements – through your own...more

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | April 2023 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights significant regulatory activity for April 2023. We discuss several criminal and civil enforcement actions related to the Anti-Kickback Statute (AKS) and the...more

Troutman Pepper Locke

DOJ's New Voluntary Self-Disclosure Policy Raises More Questions Than It Answers

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On February 22, 2023, the Department of Justice (DOJ) issued a press release highlighting the new Voluntary Self-Disclosure (VSD) Policy for U.S. Attorney’s Offices (USAOs). The DOJ developed this policy, which is applicable...more

McGuireWoods LLP

CMS Streamlines Stark Law Self-Disclosures

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The Centers for Medicare & Medicaid Services recently announced updates to the voluntary self-referral disclosure protocol (SRDP), including revisions to streamline SRDP submissions. Providers and suppliers may report and...more

Mintz - Health Care Viewpoints

EnforceMintz — Significant 2022 Regulatory and Policy Developments

From an agency guidance and regulatory developments perspective, 2022 was fairly quiet until the latter part of the year. Consistent with past practice, the Office of Inspector General for the Department of Health and Human...more

Bass, Berry & Sims PLC

False Claims Act Fundamentals: Self-Disclosures

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When healthcare providers and other government contractors are subject to scrutiny for bills submitted to the government, it is often the result of a whistleblower complaint filed under the qui tam provisions of the False...more

Health Care Compliance Association (HCCA)

[Virtual Event] Healthcare Enforcement Compliance Conference - November 7th - 9th, 8:55 am - 3:30 pm CST

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us virtually at HCCA’s Annual Healthcare Enforcement Compliance...more

Saul Ewing LLP

HHS OIG Releases Updated Health Care Fraud Self-Disclosure Protocol

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On November 8, 2021, the United States Department of Health and Human Services (HHS) Office of Inspector General (OIG) released an updated Self-Disclosure Protocol (SDP) (here). The revision of the SDP is an important...more

Burr & Forman

Health Care E-Note - November 2021

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Helpful hints - OIG Updates Health Care Fraud Self-Disclosure Protocol (“SDP”)  - On November 8, 2021, the OIG issued an updated SDP to providers, which included clarifications of existing guidance and increased the minimum...more

Snell & Wilmer

HHS Office of Inspector General Issues Important Update to Self-Disclosure Protocol

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For the first time since 2013, on November 8, 2021, the Health and Human Services Office of Inspector General (“HHS-OIG” or “OIG”) made a number of significant updates to its Health Care Fraud Self-Disclosure Protocol...more

Troutman Pepper Locke

Modifications to OIG’s Health Care ‎Fraud Self-Disclosure Protocol Provides Additional ‎Benefits for ‎Reporting

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“Houston, we have a problem:” words no in-house counsel ever wants to hear, especially regarding potential compliance issues with federal fraud prevention statutes and regulations. Fortunately, the Office of the Inspector...more

Ruder Ware

Apply the 60-Day Rule to Medicaid Overpayments

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The Affordable Care Act requires any person who has received an overpayment from certain defined government health programs to report and return the overpayment within 60 days after the overpayment is identified. If an...more

Baker Donelson

OIG Finalizes CMP Regulations, Largely as Proposed

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On December 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) finalized [PDF] its proposal to update the civil monetary penalty (CMP) regulations – namely, incorporate new CMP authorities...more

BakerHostetler

Summer Fraud and Abuse Roundup

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Now that the kids are back in school and summer vacations are in the rearview mirror, it’s time to catch up on recent fraud and abuse developments. The federal government was busy this summer negotiating a pair of settlements...more

King & Spalding

CMS Seeks Comment on Self-Disclosure Protocol Form

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On May 6, 2016, CMS published an information collection request notice regarding the existing Medicare self-referral disclosure protocol (SRDP). Specifically, CMS intends to streamline the current SRDP and revise the...more

Baker Donelson

CMS Issues FAQs Regarding Self-Referral Disclosure Protocol

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CMS has released its responses to eight frequently asked questions [PDF] regarding its Self-Referral Disclosure Protocol (SRDP). The questions fall into three categories, listed below, and respond to issues that are often...more

Poyner Spruill LLP

Shorts on Long Term Care - June 2013

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In this issue: - What’s Up With Nursing Facility “Mandatory” Corporate Compliance Programs? - Updated OIG Exclusion Guidance Spells Out Recommended Employee Screening Procedures - General Assembly Calls...more

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