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 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…
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…
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…
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…
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…