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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 the Department of Justice making a determination of the adequacy as a result of an investigation for alleged misconduct. To set benchmarks for an effective

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 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) will pay $1.4 Million to resolve False Claims Act allegations for knowingly providing coupons to Medicare beneficiaries to waive or reduce co-pays for purchasing more

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 from an immediately related provider, any of their associates or their professional corporations. As part of Stark I in 1989, self-referrals for clinical laboratory services

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 clients in preparing the front office. Here are some recommendations to ensure that proper steps are taken: Immediately contact your supervisor, manager and/or Compliance Officer

Avoiding Overutilization vs. Patient Satisfaction: What’s a provider to do?

An increasingly important issue for many providers is the dilemma of providing care that is satisfactory to the patient while avoiding overutilization and its effect on reimbursement.   Unfortunately, the patient’s perceived satisfaction may not be a result of receiving the best quality of care and in some cases may be due to inappropriate or wasteful

Are You Aware of the Updated CMS Timeline for Meaningful Use?

Recent CMS modification allows more flexibility in certified EHR technology for 2014. Participation by providers will likely increase as will the ability to meet objectives such as e-prescribing, reporting quality measures and checking lists of drug interactions and drug allergies. Eligible providers can use the 2011 Edition CEHRT or a combination of 2011 and 2014

OIG Special Fraud Alert Regarding Laboratories Payments to Referring Physicians

The OIG scrutinizes referring physician and laboratory arrangements. Two scenarios that involve transfer of value from laboratories to physicians are highlighted. These scenarios could represent possible fraud and abuse under the anti-kickback statute.   Specifically, this addresses blood specimen collection, processing, and packaging and submission of patient data to a registry or database. The anti-kickback statute offers