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…
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…
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.…
How would your staff react to an auditor or investigator?
Audits and investigations are stressful events either with or without prior notice. Medical staff should be prepared for an unannounced visit. First Healthcare Compliance provides a sample policy that assists…
$22 M of Potential Fraud, Waste and Abuse Discovered in 2012 Medicare Ophthalmology Claims
In 2012, approximately 49 million Medicare claims were related to screening, diagnosis or treatment of cataracts, wet acute macular degeneration and/or glaucoma. Medicare paid approximately $3.5 billion for these particular…
Have You Reviewed the OIG 2015 Workplan?
The 2015 Workplan of the Office of the Inspector General highlights important areas for providers including medical necessity of services billed, payment review, exclusions, and incentive payments. Determination of the…
What is the Wall of Shame?
As part of HITECH, any breach of over 500 individuals will be posted on “The Wall of Shame” on the HHS website. It is important for covered entities to be…