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Office of the Inspector General Federal Health Care Programs (FHCP) Health Care Providers

Holland & Hart LLP

FMV for Provider Contracts: Regulatory Standards

Holland & Hart LLP on

As a general rule, healthcare employers are required to pay employed physicians and other contracted providers fair market value (FMV) for their services, but many employers do not understand relevant regulatory standards. ...more

Harris Beach PLLC

OIG February 2024 Enforcement Actions

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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

Harris Beach PLLC

Office of Inspector Warns Against Proposed Surgeon-owned Turnkey Intraoperative Neuromonitoring Business

Harris Beach PLLC on

In a rarely seen “unfavorable” advisory opinion, the United States Department of Health and Human Services Office of Inspector General (“OIG”) recently warned that an entity’s (“Requestor”) proposal to assist surgeons in...more

ArentFox Schiff

OIG Again Concludes That Online Health Care Provider Marketplace Does Not Violate Fraud and Abuse Laws

ArentFox Schiff on

In Advisory Opinion No. 23-04, the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) analyzed certain proposed changes to the functionality of a health care technology company’s online...more

Morgan Lewis

OIG Approves Per-Click Marketing Arrangement Involving Online Healthcare Directory

Morgan Lewis on

The US Department of Health and Human Services Office of Inspector General (OIG) recently released Advisory Opinion No. 23-04, which found that fraud and abuse risks were sufficiently low in light of certain safeguards to...more

King & Spalding

OIG Issues Favorable Advisory Opinion Regarding Use of Online Directory to Find Healthcare Providers

King & Spalding on

On July 11, 2023, OIG posted Advisory Opinion 23-04 regarding the use of an online healthcare directory for Federal healthcare program beneficiaries to find and book appointments with medical providers. Requestor sought OIG’s...more

Kerr Russell

OIG Special Fraud Alert: Seven Suspect Characteristics of Fraudulent Telemedicine Arrangements

Kerr Russell on

It is no surprise that the use of telemedicine as a means of providing patients with access to medical care has increased significantly in recent years. Likewise, the number of telemedicine companies offering a broad range of...more

Cozen O'Connor

Sham Transactions in Digital Health Industry

Cozen O'Connor on

In its recently published Special Fraud Alert, the Office of Inspector General (“OIG”) presented a list of suspect characteristics related to arrangements with telehealth and telemedicine companies, which may help determine...more

Harris Beach PLLC

Gift Cards For Medicare Patients Not Inducements, OIG Opines

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The Department of Health and Human Services’ Office of Inspector General (“OIG”) has offered an opinion on providing a gift card to certain Medicare Advantage plan enrollees who complete specific steps in an online patient...more

Proskauer - Health Care Law Brief

OIG Issues Special Fraud Alert Regarding Telemedicine Arrangements

On July 20, 2022, the Office of Inspector General for the Department of Health and Human Services (“OIG”) issued a special fraud alert (“Alert”) advising “practitioners to exercise caution when entering into arrangements with...more

Arnall Golden Gregory LLP

Analysis of Recent OIG Advisory Opinion on Employment of Excluded Individuals

The Department of Health and Human Services, Office of Inspector General (OIG) recently released a favorable advisory opinion, OIG Advisory Opinion No. 22-11 (the “Opinion”), analyzing the proposed employment of an individual...more

Rivkin Radler LLP

OIG Issues Favorable Advisory Opinion On Hospital/Physician Joint Venture ASC

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In a recent advisory opinion, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) concluded that certain investments by a health system, manager and physicians in an ambulatory surgery center...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance 28, no. 38: News Brief - October 2019 #3

Report on Medicare Compliance 28, no. 38 (Oct. 28, 2019) - - Doctors Hospital of Augusta in Georgia agreed to pay $180,000 in a civil monetary penalty settlement over alleged violations of the Emergency Medical Treatment...more

Cooley LLP

Blog: OIG Publishes Advisory Opinion on an Arrangement Involving an Excluded Individual

Cooley LLP on

In OIG Advisory Opinion No.19-05, the Department of Health and Human Services Office of the Inspector General (OIG) concluded that it would not impose sanctions against a requestor under the civil monetary provision of the...more

Baker Donelson

OIG's List of Excluded Individuals/Entities – What Employers Need to Know

Baker Donelson on

OIG maintains a list of all currently excluded individuals and entities called the "List of Excluded Individuals/Entities," or LEIE. Covered entities that hire – or continue to employ or work with – an individual or entity on...more

Akin Gump Strauss Hauer & Feld LLP

OIG Approves Manufacturer Loaning Smartphones as Appropriate Patient Assistance to Support Digital Medicine

On January 29, the Health and Human Service Office of Inspector General (OIG) released new guidance that sheds further light on the types of patient assistance that may be provided under the “Promotes Access to Care”...more

Baker Donelson

OIG Advisory Opinion 18-11 Offers Rare Insight to Safe Harbor for Price Reductions Offered to Eligible Managed Care Organizations

Baker Donelson on

The Office of Inspector General (OIG) confirmed in Advisory Opinion No. 18-11 that the safe harbor for Price Reductions Offered to Managed Care Organizations applies to "any remuneration," not just price reductions or...more

Baker Donelson

OIG Allows Free and Reduced-Cost Services to Strained Caregivers in Advisory Opinion 18-05

Baker Donelson on

In what is becoming a steady trend, the Office of Inspector General (OIG) published another favorable opinion for an arrangement seeking to implement programs that support and engage family members who are increasingly...more

Baker Donelson

Advisory Opinion 18-03 Confirms OIG's Focus on Telehealth

Baker Donelson on

In prior articles regarding the OIG's Work Plan (July 2017 and November 2017) and its recent telehealth claim audit, we have noted how telehealth is clearly on the OIG's radar. Now, the first advisory opinion addressing...more

Baker Donelson

Nursing Facility Discounts Approved in OIG Advisory Opinion 17-08

Baker Donelson on

The OIG created an opening for nursing facility discounts to private payors when it approved a startup company's proposal to create a network of nursing facilities willing to offer discounts on the daily rates charged to...more

Holland & Knight LLP

OIG Issues Letter Declining to Impose Administrative Sanctions for Provision of Certain Free Drugs

Holland & Knight LLP on

On Jan. 4, 2018, the HHS Office of Inspector General (OIG) issued an open letter containing guidance regarding the provision of certain free drugs to federal healthcare program beneficiaries. Specifically, the OIG stated that...more

Bracewell LLP

Nationwide Healthcare Prosecutions Targeting an Array of Practices . . . Is "Just The Beginning"

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On July 13, 2017, the Department of Justice ("DOJ"), in conjunction with the Department of Health and Human Services ("HHS"), continued its annual tradition of coordinating the filing of charges and sweeping arrests in...more

Mintz - Health Care Viewpoints

DOJ and OIG Announce Largest Ever National Health Care Fraud Takedown; Focus on Opioids

Continuing its annual tradition, the U.S. Department of Justice (“DOJ”) and the U.S. Department of Health and Human Services (“HHS”) announced last week the largest ever health care fraud enforcement action by the Medicare...more

Ruder Ware

Excluded Party Cases Dominate OIG Published Self Disclosure Settlements

Ruder Ware on

In 2013, the HHS Office of Inspector General issued revised protocols outlining the process through which health care providers are able to self-disclose and resolve potential liability under the OIG’s civil monetary penalty...more

Baker Donelson

OIG Updates Permissive Exclusion Criteria – Suggests Compliance Programs Are Expected

Baker Donelson on

On April 18th, the Office of Inspector General (OIG) issued updated guidance describing the factors it will consider in determining whether to exercise its permissive authority to exclude individuals and entities from federal...more

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