OIG’s Update to the Provider Self-Disclosure Protocol Offers Expanded Detail...
The updated Provider Self- Disclosure Protocol (SDP) issued April 17, 2013 by the OIG expanded and updated the original SDP issued on October 30, 1998 and the OIG's Open Letters to health care...
View ArticleOIG Exclusion Update: The Who, What, When, Where, and Why
The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently released an updated Special Advisory Bulletin1 covering the scope and effect of exclusion from Federal...
View ArticleProposed Amendment to False Claims Act: Relief for Innocent Mistakes?
Health care providers and suppliers are well aware that they are living in a world of increased enforcement and that the Federal government has a growing arsenal of tools it uses to enforce the Federal...
View ArticleOIG Report Revives Debate over Critical Access Status
On August 15th, the Office of Inspector General (OIG) released a report sure to add fuel to the continuing debate over Medicare payments to rural providers: “Most Critical Access Hospitals Would Not...
View ArticleAddressing Stark Liability: New FAQs Provide Additional Food for Thought
The Centers for Medicare and Medicaid Services ("CMS") recently released eight frequently asked questions concerning the Self-Referral Disclosure Protocol ("SRDP"). The SRDP is a product of the Patient...
View ArticleSunset of the Stark and Anti-Kickback EHR Donation Exceptions
In 2006, CMS and the OIG promulgated a Stark exception and an Anti-Kickback safe harbor to encourage the development and adoption of interoperable electronic health record systems in communities. The...
View ArticleUpdate: EHR Donation Sunset Extended
At long last, the Office of Management and Budget (OMB) approved final rules extending the sunset on the Stark exception and an Anti-Kickback safe harbor. As addressed previously in this Health Law...
View ArticleOIG Advisory Opinion Provides Additional Guidance on Supplier's/Provider's...
Much confusion surrounds the issue of whether or not a Medicare supplier or provider may charge individuals or payors other than Federal health care programs less than its usual charges. A recent OIG...
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