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McBrayer Blogs
Showing 31 posts in Office of Inspector General of the United States Department of Health and Human Services (OIG).
OIG Guidance for Healthcare Boards
In April, the Office of the Inspector General for the U.S. Department of Health and Human Services (“OIG”), in conjunction with the American Health Lawyers Association, the Association of Healthcare Internal Auditors, and the Health Care Compliance Association, released “Practical Guidance for Health Care Governing Boards on Compliance Oversight.” Rather than merely discussing aspirational goals or stating governing principles, the guide lives up to its name in giving practical suggestions for how health care governing boards oversee compliance programs, a true product of a partnership between the OIG and associations that represent those regulated by the office. The document stressed new compliance challenges for healthcare governing boards, such as value-based payment systems and the effect of ever-expanding publicly available data (under the Sunshine Rule, for instance). The guidance covered specific topic areas of concern, each of which will be discussed briefly. More >
HHS OIG RELEASES FISCAL YEAR 2015 WORK PLAN
Recently, the Office of Inspector General of the United States Department of Health and Human Services (“OIG”) released its Fiscal Year 2015 Work Plan summarizing its oversight and enforcement priorities for the 2015 Fiscal Year. Here are some highlights from the Work Plan. More >
Changes Proposed for Anti-Kickback Statute
It has been said before—healthcare is changing. Most often providers must adapt their practices to comply with governing regulations. Sometimes, governing regulations must be revised to adapt to providers practices. And on occasion, governing regulations must be revised to be consistent with other governing regulations. This is one of those occasions. More >
Labs & Referring Physicians Take Note of OIG’s Special Fraud Alert
Recently, the U.S. Department of Health & Human Services, Office of Inspector General (“OIG”) issued a Special Fraud Alert (“Alert”) entitled, “Laboratory Payments to Referring Physicians.” The Alert focuses on (1) Specimen Processing Arrangements and, (2) Registry Arrangements. These arrangements, according to the OIG, pose substantial risks for fraud and abuse under the federal Anti-Kickback Statute. More >
All Eyes on Hospice Care
In 2013, the Department of Justice (“DOJ”) and Office of Inspector General (“OIG”) charged the nation’s largest for-profit hospice chain, Vitas Innovative Hospice Care (“Vitas”), with false Medicare billings, inappropriately admitting patients with “aggressive marketing tactics,” and misleading patients and families about Medicare hospice benefits. This suit is just one of many recently filed against hospice providers, indicating that they are being watched keenly by enforcement authorities and government agencies. More >
2014 Work Plan for SNFs, Hospice & Home Health Services
If you are a physician and want to know the specific initiatives in the OIG’s 2014 Work Plan applicable to you, check out the post from earlier this week. Today, we will be examining the OIG’s enforcement priorities for skilled nursing facilities (“SNF”), hospice, and home health services. More >
2014 Work Plan Highlights for Physicians
On January 31, 2014, the Office of Inspector General (“OIG”) finally released its Work Plan for fiscal year 2014. The Work Plan is a dense summary of the OIG’s various enforcement priorities for the year. This overview is specifically for physicians, hospitals, and other health care providers. Some of this year’s plan’s significant focus areas are discussed below. More >
Does the Shutdown “Shut Down” Health Care?
The ongoing partial federal government shutdown that began on October 1, 2013, was initiated in an effort to defund the Affordable Care Act (“ACA”). Now, it seems that the shutdown is affecting everything but the ACA. More >
Nearly Two-Thirds of CAHs’ Status in Jeopardy
On August 15, 2013, the Office of the Inspector General of the Department of Health and Human Services (“OIG”) released a report entitled “Most Critical Access Hospitals Would Not Meet the Location Requirements if Required to Re-enroll in Medicare” (“Report”). If the recommendations in the Report are fully executed, it would cause a detrimental blow to rural hospitals. There are approximately 1,300 critical access hospitals (“CAHs”) currently in operation. More >
Final Rule for Long-Term Care Facilities and Hospice Providers Becomes Effective August 26th
On June 27, 2013, CMS published its final rule for hospice agreements with long-term care (“LTC”) providers. LTC facilities are now required to have written agreements specifying what services the hospice and LTC provider will provide to nursing home residents receiving hospice care. This new Condition of Participation (CoP) aims to improve the quality and consistency of care between LTC and hospice providers by specifically defining responsibilities and roles. The agreement must be signed by authorized representatives for both the LTC facility and hospice before hospice care can be provided to patients. The effective date is August 26, 2013. More >
