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McBrayer Blogs
Showing 4 posts from November 2015.
Up, Up and Away: Penalties and CMPs to be Adjusted for Inflation
As part of the recent bipartisan budget deal, the Federal Civil Penalties Inflation Adjustment Improvements Act of 2015 (the “Improvements Act”) requires that all federal agencies make inflation-based adjustments to all civil monetary penalties (CMPs) within their jurisdictions beginning no later than August 1, 2016. In the health care context, the legislation means that the penalties available to the government under the Civil Monetary Penalties Law (CMPL), as well as the False Claims Act (FCA), must be adjusted for inflation and increased. More >
Tidbits and Takeaways from OIG’s 2016 Work Plan
The Office of Inspector General for Health and Human Services (“OIG”) recently issued its 2016 Work Plan, which sets the agenda for its auditing and investigation in the year ahead. The broad mandate of the OIG is to eliminate fraud, waste and abuse. With the requested FY 2016 budget of $417 million, the OIG will continue its fraud-fighting efforts and heighten it focus on reducing waste in HHS programs. Waste includes not only fraud, but also unnecessary services, inefficient delivery of care or service, poor quality of care or services, inflated prices, excess administrative costs, or mismanagement of grant or contract funds. With a 2015 track record of $3 billion in recoveries; 4,112 provider exclusions from participation in federal health care programs; 925 criminal actions and 682 civil and administrative enforcement actions and a return on investment of $8 for every $1 spent, the OIG is a force to be avoided. The yearly work plan provides a list of priorities for the office, and in turn gives providers insight into areas of concern in practice. The following areas are on OIG’s radar for the coming year: More >
KBML Issues Guidance to Help Physicians Get the Most out of MOST
The Kentucky Board of Medical Licensure (“KBML”) issued a recent opinion regarding the Medical Orders for Scope of Treatment (“MOST”) form. The stated purpose of the opinion is to “encourage and promote clarification of a patient’s treatment preferences into medical orders for care; and…encourage and promote transfer of information among healthcare professionals in a reliable and consistent format.” These goals coincide with the broader focus by both the healthcare industry and government at both federal and state levels in improving the continuum of care of patients through patient-centered care and information sharing. The MOST form, in particular, also evinces a focus on patient preference for end-of-life care. More >
