As the end of the year approaches, keep in mind that all breaches of unsecured protected health information involving less than 500 individuals must be reported to the Secretary at…
Beware of Individual Liability: Yates Memo
On September 9, 2015, the Department of Justice (DOJ) Deputy Attorney General Sally Yates released a policy memorandum, titled “Individual Accountability for Corporate Wrongdoing,” also known as the “Yates Memo.”…
OIG WORKPLAN 2016
The Office of the Inspector General (OIG) is responsible for protecting the integrity of the programs in Health and Human Services against fraud, waste and abuse as well as recommending…
Overview of a Corporate Integrity Agreement (CIA)
Health care fraud recoveries for fiscal years 2009- 2014 exceeded previous records with five straight years of more than $2 billion in annual recovery from cases involving fraud and false…
Are You Prepared for the HIPAA Phase 2 Audits?
After reviewing the HIPAA Privacy case investigations from 2009-2011, the Office of the Inspector General sent a strong message to the Office of Civil Rights in regard to the administration…
Don’t Pay for Free Workplace Posters That Are Required By Law
Employers are required to advise employees of their federal rights in the form of displaying federally required posters in the workplace. Compliance with these federal requirements is necessary to avoid…
Stark vs. Anti-Kickback: A Quick Comparison
The Federal Anti-Kickback Statute and the Stark Law are often confused because both laws deal with remuneration related to improper referrals. Large groups and multi-specialty practices must make an effort…
Billing Care Plan Oversight Risks
Care Plan Oversight describes the physician or other healthcare professional’s supervision of patients in hospice, nursing facilities or those receiving care through home health agencies. CPO reimbursement covers initial certification,…
Are You Aware of the Whistleblower Provisions of the False Claim Act ?
The whistleblower provisions of the False Claims Act have lead to several newsworthy cases in recent years. Just a few days ago, the Justice Department announced that KMART Corporation (Kmart)…
Complying with Stark Law: Can you bill Medicare when treating your family members?
The treatment of family members falls under General Exclusions from Coverage under Medicare. No payment will be made for items or services for a family member when the charge is…