oig

Will Xiulu Ruan v. United States Finally Bring Some Sanity to Interpretations of the Controlled Substances Act?

(May 2, 2022): The Supreme Court last addressed violations of 21 U.S.C. §841 by a medical practitioner in 1975.[1] Since that time, several circuit courts have taken different approaches when construing the scienter requirements to prove a Controlled Substance Act violation, and how a jury may be instructed when deciding a case.  Hopefully, clarification of […]

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The Criminalization of Pain – In 2022, DOJ is Aggressively Investigating and Prosecuting MDs, NPs and PAs for Violations of the Controlled Substances Act

(April 19, 2022): Despite our government’s best efforts, opioid overdose deaths in America are continuing to spiral out of control. According to the U.S. Centers for Disease Control and Prevention (CDC), during the period April 2020 through April 2021, the number of overdose deaths were more than 30% higher than the previous year. While many

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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

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? Read More »

Dental Practice Audits are on the Rise — Protect your Interests!

(October 11, 2016): More than 45 million children receive government-funded dental care served under Medicaid and CHIP programs. This equates to approximately 1 out every 3 children in the country. The dental care provided includes screening services and other preventive, diagnostic, and treatment services that are medically necessary and properly documented. Under the mandatory Early

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How to Implement a Compliance Plan in Your Practice

(September 17, 2015): Despite the fact that Medicare and Medicaid requires that participating providers implement a compliance plan, most small providers have yet to complete the necessary steps to accomplish this requirement.  “My office manager went to a continuing education program, and she’s come back telling me we need a compliance program. I don’t know about

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Are More Home Health Program Integrity Initiatives on the Horizon?

(April 22, 2015): Late last month, the Department of Health and Human Services, Office of Inspector General (HHS-OIG) released its 2015 “Compendium of Unimplemented Recommendations” (Compendium). Published annually, the Compendium sets out the top 25 program integrity issues previously identified by HHS-OIG that are expected to “most positively impact HHS programs in terms of cost

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CMS and Contractors Must Address EHR Fraud Vulnerabilities

(February 7, 2014): A new report from the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) finds that the Centers for Medicare and Medicaid Services (CMS) and its contractors have adopted few Medicare program integrity practices to address electronic health record (EHR) fraud vulnerabilities. These EHR fraud vulnerabilities include

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The Latest OIG Report on E/M Coding Finds that Coding Practices are Trending Higher

(June 15, 2012): Evaluation and Management (E/M) coding has been the subject of substantial scrutiny in Medicare post-payment audits and appeals for many years. When a reviewer for the Center for Medicare & Medicaid Services (CMS) audits an E/M claim, the reviewer often appears to utilize the AMA CPT Code Book to assess the proper

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2011: The Year of Compliance – Medicare Payment Suspension Actions

(January 26, 2011): Medicare payment suspension action can prove disastrous for your practice or home health agency. How did we get to this point? The recent debate over healthcare in this country has drawn attention to healthcare costs as well as the relationship between healthcare providers and the Federal government. With healthcare costs steadily on

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Provider Exclusion Screening / OIG Screening Practices are a Significant Risk

(December 11, 2010): Has your practice conducted exclusion screening / OIG screening on all of you employees?Earlier this week, HHS-OIG announced that it had assessed significant civil monetary penalties against a health care provider that employed seven individuals who the provider “knew or should have known” had been excluded from participation in Federal health care

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