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Healthcare Audits Department of Health and Human Services (HHS)

Husch Blackwell LLP

OIG Announces 2025 Work Plan Review: What Clinical Laboratories Need to Know About Medicare Payments for Diagnostic Lab Tests

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In June 2025, the U.S. Department of Health and Human Services Office of Inspector General (OIG) announced a new item in its Work Plan: “Medicare Payments for Clinical Diagnostic Laboratory Tests in 2024.” This annual review,...more

McDermott Will & Emery

This Week in 340B: February 4 – 10, 2025

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Find this week’s updates on 340B litigation to help you stay in the know on how 340B cases are developing across the country. Each week we comb through the dockets of more than 50 340B cases to provide you with a quick...more

Kerr Russell

The Difference Between ‘Non-Covered’ vs. ‘Disallowed’ Services

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Question: I have had several colleagues describe their experience with dental plan audits. All of them have had to pay something back. Sometimes they say this is due to a service being deemed a “noncovered service.” Other...more

McDermott Will & Emery

This Week in 340B: January 14 – 20, 2025

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Find this week’s updates on 340B litigation to help you stay in the know on how 340B cases are developing across the country. Each week we comb through the dockets of more than 50 340B cases to provide you with a quick...more

Ropes & Gray LLP

A Flurry of Healthcare Sector Cybersecurity Regulatory Developments in 2024

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2024 was a record year for cyberattacks in the healthcare sector. According to the Breach Portal maintained by the U.S. Department of Health and Human Services (“HHS”) Office of Civil Rights (“OCR”), to date this year, there...more

Brooks Pierce

OIG Recommends Changes to HIPAA Audit Program to Strengthen Data Protections, Implications for Regulated Entities

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The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) is required by law to perform periodic audits of covered entities and business associates to ensure their compliance with HIPAA Security Rule...more

Foley & Lardner LLP

Compliance Compass: The Erlanger Complaint – A Cautionary Reminder About the Importance of FMV

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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

Ankura

OIG Testimony Puts a Spotlight on Clinical Documentation and Payer Risk

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In recent testimony before the United States House Committee on Energy and Commerce Subcommittee on Oversight and Investigations, Christi A. Grimm, Inspector General of the Department of Health and Human Services (HHS)...more

ArentFox Schiff

Fast Five: Important Law and Policy Updates for US Health Care Transactions

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With the end of the first quarter of 2024, we highlight five developments, changes, or challenges that health systems, hospitals, nursing homes, clinics, physician practices, health insurers, and other health care providers,...more

NAVEX

Addressing Cybersecurity Expectations in Healthcare

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2024 is shaping up to be a very active year for regulatory and enforcement developments in the healthcare industry – developments that concern not just hospitals and nursing facilities, but many non-healthcare companies as...more

Gardner Law

Highlights from OIG’s New Compliance Program Guidance

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The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) released an important new compliance resource in November 2023. The HHS OIG’s new General Compliance Program Guidance (GCPG) is intended...more

McDermott Will & Emery

HIPAA Compliance 101: Lessons from a Recent OCR Settlement

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The US Department of Health and Human Services Office for Civil Rights (OCR) recently announced a settlement with a community hospital resolving an investigation under the Health Insurance Portability and Accountability Act...more

King & Spalding

OIG Publishes the Spring 2023 Semiannual Report to Congress

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OIG released its Semiannual Report to Congress (the Report) which summarizes the agency’s activities from October 1, 2022, through March 31, 2023 (the Reporting Period). Among other accomplishments, the Report highlights...more

Ballard Spahr LLP

HHS OIG to Review CMS Citations

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Summary - The Department of Health and Human Services Office of Inspector General (HHS OIG) has announced its intention to comprehensively review nursing home citations issued by the Centers for Medicare and Medicaid...more

Baker Donelson

OIG Hospital Compliance Audits: Is Your Number Up? Are You Ready?

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In its Work Plan for Fiscal Year 2012, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) announced it would begin reviews of Medicare payments to hospitals to determine compliance...more

Womble Bond Dickinson

Is Your HIPAA Compliance Program Ready for the FTC?

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Everyone in healthcare knows that the next round of HIPAA audits is coming. Covered entities and business associates have long been advised to review and update their HIPAA security risk analyses, have business associate...more

Robinson+Cole Data Privacy + Security Insider

OIG report spurs OCR to announce phase 2 audits

On September 29, it was revealed that the HHS Office for Civil Rights (OCR) will commence Phase 2 of its HIPAA audit program in “early 2016.” OCR’s revelation regarding the Phase 2 audits, which had been the subject of...more

Holland & Knight LLP

HHS Issues Proposed 340B Program Omnibus Guidance: Five Things to Watch

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The 340B Drug Pricing Program (340B Program), established by Section 602 of the Veterans Health Care Act of 1992, is administered by the Health Resources and Services Administration (HRSA) of HHS. The 340B Program requires...more

Orrick, Herrington & Sutcliffe LLP

Don’t Wait for It; Recent HIPAA Enforcement Action Signal More to Come in Phase 2 Audits

Officials at the U.S. Department of Health and Human Services Office of Civil Rights (HHS OCR) have recently selected a vendor to conduct the second wave of HIPAA audits. These so-called “Phase 2 Audits” are set to commence...more

BakerHostetler

340B Guidance: Eight Key Points Covered Entities Should Consider

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On August 27, 2015, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), released the 340B Drug Pricing Program Omnibus Guidance (Guidance). Referred to...more

Foley & Lardner LLP

Recent OIG Audits of Home Health and Hospice Surveys May Signal Increased Scrutiny on Worker Qualifications

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Recent audits by the Department of Health and Human Services Office of Inspector General (“OIG”) conclude that state survey agencies in a number of states and a leading national accrediting agency serving the home health and...more

Faegre Drinker Biddle & Reath LLP

Got A Complaint About RAC Audits? Get In Line

Criticism of the RAC (recovery audit contractor) program is becoming a national pastime. Needless to say, hospitals hated the program from the very beginning. And little wonder. The program pays private contractors a...more

King & Spalding

Third Circuit Holds Judicial Review of Extrapolated Overpayment Determinations is Precluded

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On February 12, 2014, the U.S. Court of Appeals for the Third Circuit held that Federal courts do not have jurisdiction to review HHS’s determination of a “sustained or high level of payment error,” one of two possible...more

King & Spalding

GAO Calls For Consistency Among Medicare Contractors Postpayment Claims Review

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The U.S. Government Accountability Office (GAO) recently published the results of a study examining the effectiveness of CMS’s contractors that conduct postpayment claims reviews to identify improper payments (i.e., Medicare...more

The Volkov Law Group

Protecting Your Hospital From Over-Utilization Prosecutions

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The government has been increasing its focus on healthcare fraud involving “quality” of care. This is an extremely difficult issue, especially for prosecutors. It is very difficult to define “quality” standards and then...more

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