OIG Special Fraud Alert: Anti-Kickback Risks for Physician Arrangements with Laboratories

On June 25, 2014, the Office of Inspector General (OIG) for the Department of Health and Human Services issued a Special Fraud Alert addressing two types of relationships that could potentially violate the anti-kickback statute. The OIG Special Fraud Alert specifically addresses anti-kickback risks associated with clinical laboratories providing remuneration to physicians to collect, process, and package patients’ specimens and also addresses payments to physicians for activities related to patient registries. Anti-Kickback Risks Associated with Specimen Collection, Processing and Packaging… Read More >

AHA Asks for Relief from OIG Medicare Audits

The American Hospital Association (AHA) submitted a letter to CMS dated June 2, 2014 stating concerns regarding Medicare audits or “hospital compliance reviews” performed by the Office of Inspector General (OIG) Office of Audit Services.  The AHA also takes issue with the use of extrapolation in these Medicare audits. The AHA urged CMS to put an end to these OIG Medicare audits for the following reasons: The OIG audits are redundant to the Recovery Audit Contractor (RAC) reviews including the… Read More >

OIG Allows Medigap Policy to Provide Premium Credits for Patients Using Network Hospitals

In Advisory Opinion 14-02, released on February 20, 2014, the Office of Inspector General (OIG) advised that it would not impose sanctions pursuant to the anti-kickback statute and civil monetary penalty law for the arrangement between a licensed offeror of Medigap policies and preferred provider organizations (PPOs) that contract with network hospitals.  As part of the arrangement, the network hospitals would provide up to a 100 percent discount on Medicare Part A inpatient deductibles that would otherwise be paid by… Read More >

OIG Report finds CMS and its contractors failed to address fraud vulnerabilities in electronic health records

A recent report by the Office of Inspector General (OIG) concluded that CMS and its contractors have failed to adopt program integrity measures focused on fraud vulnerabilities with the use of electronic health records (EHR).  Recognizing that EHR technology may make it easier for individuals to perpetrate fraud, the OIG found that CMS and its contractors had not adequately adjusted their review practices. The report addressed several specific ways in which EHR documentation practices can make it easier for individuals… Read More >