News & Analysis as of

Enforcement Actions Department of Health and Human Services (HHS) Civil Monetary Penalty

Venable LLP

OIG Reminds Us that Flat Fee Business Arrangements Aren’t Immune from AKS Scrutiny

Venable LLP on

On July 1, 2025, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 25-08, concluding that a medical device manufacturer’s proposed payment to access a...more

Saul Ewing LLP

OCR Imposes $200,000 Civil Money Penalty Against HIPAA-Covered Entity

Saul Ewing LLP on

On March 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil money penalty (“CMP”) of $200,000 against Oregon Health & Science University (“OHSU”) for failing to...more

Health Care Compliance Association (HCCA)

We’ll Take the Fine: OCR’s ‘Unwarranted,’ Costly Demands Prompted Hospital’s $538K Payment

The saga that led Children’s Hospital Colorado to accept a fine of more than $500,000 imposed by the HHS Office for Civil Rights (OCR) began on July 11, 2017, when a physician’s email account containing details on 3,300...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Private Equity Throws FCA Enforcement Off-Kilter

Over the last 15 years, private equity (“PE”) firms have invested hundreds of billions of dollars in the healthcare sector, infiltrating every corner of the industry from emergency rooms and labs to billing providers and...more

Mintz - Health Care Viewpoints

EnforceMintz —Could the Supreme Court’s Decision in Jarkesy Mean the End to HHS Civil Monetary Penalty Authorities as We Know...

Last June, the Supreme Court issued its decision in Securities and Exchange Commission v. Jarkesy, which holds that the Seventh Amendment entitles a defendant to a jury trial when the Securities and Exchange Commission (SEC)...more

Saul Ewing LLP

Two CMPs and One Settlement Close Out 2024 HIPAA Enforcement

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December 2024 was an active month for the U.S. Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR"). OCR announced (i) a $1.19 million civil monetary penalty ("CMP") against Gulf Coast Pain...more

Saul Ewing LLP

A “Scary” OCR CMP Imposed Upon a Solo Dental Practice

Saul Ewing LLP on

On October 21, 2024, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil monetary penalty (“CMP”) of $70,000 against a solo dental practice that provides family dental...more

Saul Ewing LLP

Medical Practice Ordered to Pay HIPAA Civil Monetary Penalty Following Acquisition

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In October 2024, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced the imposition of a civil monetary payment against Providence Medical Institute (“PMI”), a large medical...more

Saul Ewing LLP

OCR Imposes $115,200 CMP Against HIPAA-Covered Entity

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On August 1, 2024, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil monetary penalty of $115,200 against American Medical Response (“AMR”) based on a complaint that...more

Arnall Golden Gregory LLP

OCR Announces Latest in Right of Access Enforcement Actions With Imposition of Civil Monetary Penalty

On August 1, 2024, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) announced the imposition of a civil monetary penalty (“CMP”) of $115,200 collected against American Medical Response...more

Health Care Compliance Association (HCCA)

In Biggest Stark-Based FCA Settlement Ever, Indiana Hospital Pays $345M, Has Unusual CIA

Community Health Network (CHN) in Indiana has agreed to pay $345 million to settle false claims allegations that it paid over-the-top salaries to hundreds of physicians and rewarded them for their referrals in violation of...more

Bass, Berry & Sims PLC

HHS-OIG Year in Review 2023

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) is tasked with providing objective oversight to protect the integrity and promote the efficiency of Medicare, Medicaid, and more than...more

McDermott Will & Schulte

[Webinar] How Not to Lose $1M: Preparing for HHS-OIG Info Blocking Enforcement - August 15th, 1:00 pm - 2:00 pm EDT

The US Department of Health and Human Services Office of Inspector General (HHS-OIG) issued a final rule to implement its authority under the 21st Century Cures Act to investigate allegations of information blocking and...more

Alston & Bird

OIG Adds New Teeth to the Information Blocking Rule

Alston & Bird on

Our Health Care Group shares what you need to know about how the Department of Health and Human Services implemented civil monetary penalties and enforcement authority for information blocking....more

McDermott Will & Schulte

Special Report - A Million Reasons to Share: OIG’s Final Rule on Information Blocking Enforcement

On July 3, 2023, the US Department of Health and Human Services Office of Inspector General (OIG) published its long-awaited final rule implementing the 21st Century Cures Act provisions authorizing OIG to investigate claims...more

Sheppard Mullin Richter & Hampton LLP

OIG 2022 Advisory Opinions: Year in Review

The Office of Inspector General (“OIG”) within the U.S. Department of Health and Human Services (“HHS”) is responsible for detecting and preventing fraud, waste, and abuse in federal health care programs. The OIG has...more

Foley & Lardner LLP

Public Health Emergency Ends May 11: What Telehealth Companies Need to Know

Foley & Lardner LLP on

On January 30, 2023, the Biden Administration announced its intent to end the COVID-19 public health emergency (PHE) on May 11, 2023. The PHE has been in place for over three years during which time many telehealth and...more

ArentFox Schiff

Increased Federal Attention to Skilled Nursing Facility Compliance and Quality Improvement Results in Modified Program...

ArentFox Schiff on

The Biden Administration has embraced an aggressive and multi-part agenda designed to improve the safety and quality of care nationally in skilled nursing facilities (SNFs). The Biden Administration’s nursing home agenda...more

Health Care Compliance Association (HCCA)

Report on Patient Privacy Volume 22, Number 11. MD Anderson Won Against OCR, But Agency’s Response—Including on Fines—Keeps...

Report on Patient Privacy Volume 22, Number 11. (November 2022) Nearly five years passed from the time the University of Texas MD Anderson Cancer Center reported to the HHS Office for Civil Rights (OCR) that three...more

Steptoe & Johnson PLLC

OCR Enforcement of Right to Access Extends to Dental Practices

Steptoe & Johnson PLLC on

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) continues its enforcement activities to emphasize compliance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule’s...more

Clark Hill PLC

With Recent Settlements, HHS OCR’s HIPAA Right of Access Initiative Continues To Be a Focus of Enforcement

Clark Hill PLC on

OCR’s HIPAA Right of Access Initiative shows no signs of slowing down. On July 15, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced the resolution of 11 more cases at a total of...more

Saul Ewing LLP

11 Additional Providers Resolve HHS OCR Investigations Related to the HIPAA Right of Access Initiative

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On July 15, 2022, the Office for Civil Rights (OCR) within the U.S. Department of Health and Human Services (HHS) announced the resolution of eleven investigations as part of its Health Insurance Portability and...more

ArentFox Schiff

Disclosing Patient Information in Responses to Online Reviews: Recent OCR Enforcement Action Is a Cautionary Tale

ArentFox Schiff on

The HHS Office for Civil Rights (OCR) recently imposed a $50,000 civil monetary penalty on a dental practice that disclosed patient-identifying information in response to a negative online review. The case is a reminder that...more

Goodwin

OIG Alert and DOJ Enforcement Action Summary: Telemedicine Arrangements

Goodwin on

The July 20, 2022 Special Fraud Alert describes findings from what OIG describes as “dozens of investigations of fraud schemes involving companies that purported to provide telehealth, telemedicine, or telemarketing services”...more

Health Care Compliance Association (HCCA)

OCR: Current Fines Too Low to Spur Compliance; Agency Also Seeks Funding Boost, Injunctive Relief

Report on Patient Privacy 22, no. 5 (May, 2022) - Compared to other agencies, the HHS Office for Civil Rights (OCR) is a little fish in the big federal pond, but it has an outsize effect on HIPAA covered entities (CEs) and...more

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