According to an Office of Inspector General (OIG) study, less than half of all U.S. medical schools provide training on Medicare and Medicaid fraud and abuse laws. Further, the OIG study found that only two-thirds of residency and fellowship programs reported providing their residents or fellows with any …
CMS Issues New Compliance Tool for Providers
November 5, 2010 Leave a Comment
In October, CMS posted its first issue of a new educational newsletter called the “Medicare Quarterly Provider Compliance Newsletter.” This newsletter is intended to help physicians, providers, and suppliers understand how to avoid certain billing errors and other improper activities. The newsletter will …
What the OIG Guidance on Permissive Exclusion Means for Owners and Managers
October 28, 2010 Leave a Comment
For quite some time, the Office of Inspector General (OIG) has had the authority to exclude an owner, officer and/or manager of an entity convicted of certain criminal offenses or that is excluded from participation in Federal health care programs. In section 6502 of the Patient Protection and Affordable Care Act …
OIG Intends to Exclude Officers and Managing Employees of Sanctioned Entities: Limited Safety Zones
October 22, 2010 Leave a Comment
On October 20, 2010, the OIG released a notice setting forth non-binding factors the OIG will consider in assessing whether to impose permissive exclusion in accordance with section 1128(b)(15)(A)(ii) of the Social Security Act, which authorizes the OIG to exclude any officer or managing employee of a sanctioned …
OIG Approves Limited Insurance Pre-Authorization Services
October 22, 2010 Leave a Comment
On September 28, 2010, the OIG released Advisory Opinion No. 10-20, which permits a physician-owned imaging center to offer free insurance pre-authorization services for its own services. Of course, before the OIG begins its analysis, it states that the OIG’s position on arrangements where goods or services are …
Another OIG Opinion Calms Fears Government May Punish Charities Helping Poor People Dying From Brain Tumors
September 15, 2010 Leave a Comment
At first blush, the conclusion seems obvious. But OIG Advisory Opinion 10-12 reminds us that calling something “charity” doesn’t immunize it from careful scrutiny under the fraud and abuse laws. This opinion, released August 30, is the latest of several OIG opinions addressing patient assistance programs, or …