News & Analysis as of

Civil Monetary Penalty Enforcement Office of the Inspector General

Foley & Lardner LLP

Health Care Enforcement: “Tea Leaves” in the 2024 National Health Care Fraud Summer Takedown

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Each summer in recent years, the U.S. Department of Justice (DOJ) and associated fraud enforcement partners have indicted many health care defendants, in multiple cases across the country. This summer continued the tradition....more

Foley & Lardner LLP

HHS OIG: New “General Compliance Program Guidance” Provides Voluntary Steps Towards Increased Effectiveness

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In connection with the November 2023 Health Care Compliance Association’s (HCCA) Healthcare Enforcement Compliance Conference, and with acknowledgment by the Chief Counsel to the Inspector General, Rob DeConti, of the long...more

Harris Beach PLLC

HHS Office of Inspector General September 2023 Enforcement Activity

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The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country.  The enforcement actions reported...more

Holland & Knight LLP

Information Blocking Enforcement Penalties Begin Sept. 1, 2023

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The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently posted the final rule establishing civil monetary penalties (CMPs) for information blocking (IB Enforcement Rule). The Rule...more

Mintz - Health Care Viewpoints

OIG, HHS Publish Information Blocking CMP Final Rule, Enforcement Priorities

Though there has been much speculation and commentary among industry stakeholders, the Office of Inspector General (OIG) and the Office of the National Coordinator for Health Information Technology (ONC) have not yet begun...more

King & Spalding

OIG Publishes Final Information Blocking Enforcement Rule

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On July 3, 2023, OIG published its final enforcement rule (the OIG Rule) permitting imposition of civil monetary penalties (CMPs) for certain actors that engage in information blocking in violation of the information blocking...more

BakerHostetler

Steep Penalties for Information Blocking Finalized

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On June 27th, Office of the Inspector General (OIG) of the Department of Health and Human Services (HHS) posted its final rule (Final Rule), which amends the OIG’s civil monetary penalty (CMP) regulations to implement the...more

Bradley Arant Boult Cummings LLP

“Dear OIG”: The Newest Way to Attain Kickback Guidance

The Office of Inspector General (OIG) recently unveiled a quicker process to answer the healthcare industry’s most pressing questions on the Anti-Kickback Statute (AKS), allowing healthcare stakeholders to attain more timely...more

Sheppard Mullin Richter & Hampton LLP

OIG Limits Pharmaceutical Manufacturers’ Ability to Offer Drug Cost-Sharing Subsidies

On October 5, 2022, the Office of Inspector General (“OIG”) posted Advisory Opinion No. 22-19 (the “Opinion”), which limits the ability of pharmaceutical manufacturers to offer cost-sharing subsidies to Medicare Part D (“Part...more

Harris Beach PLLC

OIG Enforcement Summary: July 16, 2022 – July 31, 2022

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The following is a summary of the federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported are...more

Bass, Berry & Sims PLC

Government Appeals Decisions in 340B Contract Pharmacy Litigation

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On December 28, 2021, the federal government submitted notices to appeal three federal district court decisions related to the use of contract pharmacies under the federal 340B drug pricing program. The appeals are the latest...more

Dorsey & Whitney LLP

HHS OIG Releases an Updated Health Care Fraud Self-Disclosure Protocol

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On November 8, 2021, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released a revised Provider Self-Disclosure Protocol, renamed Health Care Fraud Self-Disclosure Protocol (“SDP”). Prior...more

Mintz - Health Care Viewpoints

Seven Takeaways from the ABA National Institute On Health Care Fraud

On May 17, 2017 the American Bar Association convened its 27th National Institute on Health Care Fraud. I have attended many of the past annual meetings, and always enjoy the presentations and the opportunity to network with...more

Cozen O'Connor

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions - October 2015

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This edition of the Cozen O’Connor Aviation Regulatory Update reports on Congress’s six-month extension of FAA’s reauthorization; new U.S. Bilateral Aviation Safety Agreements with the European Union and Canada; the FAA’s...more

Cozen O'Connor

August 2015 Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions

Cozen O'Connor on

This edition of the Cozen O’Connor Aviation Regulatory Update discusses DOT’s launch of an investigation of alleged price gouging by airlines following Amtrak train service disruption in the Northeast Corridor, the agency’s...more

BakerHostetler

HHS OIG Creates New Taskforce to Pursue Civil Monetary Penalties and Exclusions

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At the annual meeting of the American Health Lawyers Association (AHLA) held this week in Washington D.C., the U.S. Department of Health and Human Services Office of Inspector General (OIG) announced a new legal team...more

Cozen O'Connor

Five Key Proposed Changes to OIG’s CMP Authority

Cozen O'Connor on

In May and within a week of the Office of Inspector General of the Department of Health and Human Services (OIG) releasing a proposed rule to expand its exclusion authority, the agency also released a proposed rule (Rule)...more

BakerHostetler

OIG Revamps Regulations Concerning CMPs and Exclusion

BakerHostetler on

In a pair of proposed rules published in May, the HHS OIG unveiled changes to the regulations concerning OIG’s authority to impose civil monetary penalties (CMPs) and exclude individuals and entities from participation in...more

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