Compliance

The OIG Exclusion List of Individuals and Entities is Growing. What Steps are You Taking to Avoid Hiring or Contracting with an Excluded Individual or Entity?

(March 17, 2022): Over the last few months (from mid-November 2021 through mid-March 2022), the number of excluded individuals and entities on the Department of Health and Human Services, Office of Inspector General’s (OIG’s) List of Excluded Individuals/Entities (LEIE) has grown by approximately 15%. According to our friends at Exclusion Screening,[1] this rapid expansion of …

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Exclusion Screening-OIG Screening: The New “Seventh Element” of Compliance.

(May 17, 2017): Exclusion screening-OIG screening duties are now more important than ever before!  The recently issued “Resource Guide for Measuring Compliance Program Effectiveness,” a product of Office of Inspector General staff and compliance professionals roundtable discussions, reconfigures the traditional “Seven Elements of an Effective Compliance Program” by making the “Screening and Evaluation of Employees, Physicians, …

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OIG And DOJ Issue Important New Compliance Guidance

Compliance Guidance (April 14, 2017) Recently, the Office of Inspector General of the United States Department of Health and Human Services (OIG) and the Criminal Division of the Fraud Section at the United States Department of Justice (DOJ) have issued guidance on measuring the effectiveness of corporate compliance programs.  In February, DOJ placed on its …

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Under Health Care Reform Legislation, Stark Law Whole Hospital and Rural Provider Exceptions are Changing

(October 22, 2010):  It’s not exactly breaking news to anyone in the hospital industry that the U.S. Congress and the regulators at the Center for Medicare and Medicaid Services seem bent on preventing or eliminating physician referrals to hospitals in which they invest. With the passage of health reform legislation in March of this year, …

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Identity Theft — Red Flags Rule — Treating Doctors Like Banks Is Delayed Once Again

(July 5, 2010): The Federal Trade Commission (FTC) has agreed to once again delay enforcement of its illogical and onerous identity theft Red Flags rule with respect to physicians. The Red Flags rule arose under the Fair and Accurate Credit Transactions Act of 2003 and requires “financial institutions” and “other creditors” to develop written plans to …

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