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Common Elements of Corporate Integrity Agreements

A Corporate Integrity Agreement (CIA) is negotiated with a healthcare provider or entity. This type of agreement is part of a settlement of federal healthcare program investigations arising under false claims statutes. In exchange for the agreement, the OIG agrees not to exclude the provider or entity from participation in the federal healthcare programs. Implementation and oversight of CIAs require significant personnel and financial resources. 
All types of organizations and providers may be impacted including pharmaceutical companies, medical device companies, hospitals, nursing homes and long term care facilities, and medical practices. Check out our infographic to become familiar with some of the common elements found in these agreements.

Webinar Q&A Session: Exclusion Screening

First Healthcare Compliance hosted an informative webinar with Cristina Loayza, Product Manager of Precheck, titled “What Healthcare Employers Should Know About Exclusion Screening.” Click here to view the webinar. As a recap, Cristina Loayza answers the three most common questions regarding exclusion screening. Q: What is exclusion screening? Healthcare service providers who receive federal healthcare funds

Updates to the 2016 OIG Work Plan

Fighting fraud, waste and abuse continues to be the focus of the Department of Health and Human Services (HHS) and the Office of the Inspector General (OIG). Almost 80 percent of HHS’ budget is spent on Medicare, Medicaid and CHIP totaling near $985 M for FY 2015.   The ongoing goal for Center for Medicare and

OIG Policy Update: Excluding Participation in Federal Healthcare Programs

On April 16, 2016, the Office of Inspector General of the Department of Health and Human Services (OIG) issued a revised policy statement updating its criteria on excluding individuals/entities from participation in Medicare, Medicaid, and all other Federal healthcare programs. This policy statement is an update to the 1997 statement and provides insight into the OIG’s

Overpayments: Reporting and Returning Deadline

The long awaited ruling on reporting and returning overpayments is now in the Federal Register and will become effective on March 14, 2016. As stated in §401.303, an overpayment is any fund that a person has received or retained under Title XVIII of the Social Security Act to which the person, after applicable reconciliation, is

Jumpstart Your Compliance Program

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 an effective way to detect, deter and prevent wrongdoing in the healthcare setting and an ongoing system assures conformity with governing laws and regulations. An

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.” To read the full contents of the Yates Memo, click here. Essentially, the Yates Memo shifts the DOJ’s approach to fighting corporate fraud and misconduct

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 improvements to the system that would promote efficiency and efficacy within the limits of the health care laws.   Although OIG oversight includes programs such as

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 claims against federal health care programs such as Medicare and Medicaid.  Most healthcare providers are aware of significant civil liability due to recent enforcement. However,

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 and enforcement of the HIPAA Privacy Rule. The OIG recommendation is clear in the September 2015 executive summary, “OCR Should Strengthen Its Oversight of Covered