Due to the high volume of tips and complaints the Department of Health and Human Services (HHS) Office of Inspector General (OIG) receives – approximately 115,000 each year – the need for an efficient means of capturing these complaints was vital for OIG. Released to the public November 14, 2019, the newly redesigned OIG Hotline […]
In the recently released CY 2020 Outpatient Prospective Payment System (OPPS) proposed rule, the Centers for Medicare & Medicaid Services (CMS) introduced policies that, if finalized, would require hospitals to post a list of standard charges for items and services provided. This proposed rule updates the requirements set forth in the FY 2015 Inpatient Prospective […]
By Adrienne Dresevic, Esq. of The Health Law Partners, P.C., Olivia Dresevic JD expected 2020 On June 1, 2019, Joanne Chiedi assumed the role of Acting Inspector General at the U.S. Department of Health and Human Services (HHS) following Daniel R. Levinson’s resignation. Ms. Chiedi recently sat down with the Compliance Perspectives Podcast to speak […]
As of April 30, 2019, the maximum penalties for violations of the Health Insurance Portability and Accountability Act (HIPAA) have new annual limits. These updated penalties will be based on the level of culpability associated with the violation, according to the Department of Health and Human Services (HHS). Organizations that have taken measures to meet […]
The New York State Office of the Medicaid Inspector General (OMIG) maintains a Certification Program to ensure Medicaid providers are continuing proper compliance. This program works to eliminate any environment in a Medicaid provider’s system that may encourage fraud, waste, or abuse, as well as ensuring errors have the potential for self-correction if mistakes are […]
June 2018 – On June 19, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Request for Information (“RFI”) seeking public input on how to address any undue impact and burden of the physician self-referral law, 42 U.S.C. § 1395nn (the “Stark Law”). By way of background, the Stark Law addresses the concern […]
Compliance programs are mandatory (pending final regulations) for all health care organizations post-Affordable Care Act. In some states, and for some provider/supplier types, compliance programs are already mandatory. In any event, compliance programs in health care organizations are crucial in today’s overregulated environment, with qui tam attorneys, whistleblowers, regulators, and payors seeking any potential excuse to […]
Recent letters from New York’s Medicaid Fraud Control Unit (“MFCU”) to those healthcare providers in New York State who have “percentage of collection” arrangements with their outside billing companies are demanding that such providers refund money paid to them by Medicaid based on MFCU’s determination that such billing arrangements are illegal under the Medicaid law […]
Relief will (eventually) be granted to Medicare appellants. After a years-long battle, on December 5, 2016, the U.S. District Court of the District of Columbia granted mandamus relief to the American Hospital Association (“AHA”) and its co-plaintiffs. The Court requested that the parties propose actions the Secretary could take to address the backlog of pending […]
The New York State Office of the Medicaid Inspector General (OMIG) issued guidance on its requirements for Medicaid compliance, effective October 26, 2016. This Compliance Program Review Guidance (“Guidance”) will assist the Medicaid Required Provider (“Required Provider”) community in developing and implementing compliance programs that meet the requirements of Social Services Law Section 363-d (“SSL […]
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