The beginning of the New Year is a popular time for new initiatives. Many healthcare organizations are looking for ways to improve quality and reduce risk. A compliance program is…
Is Your Compliance Program Effective?
Having a compliance program in place is a start but having an effective compliance program is the goal. Proactively assessing the effectiveness of one’s own compliance program is better than…
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…
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…
LEIE: Do You Know About the List of Excluded Individuals and Entities?
The Exclusions Statute is one of five major federal fraud and abuse laws. Exclusion is an administrative remedy that is in the form of a penalty imposed on a provider.…