In-Depth Articles

The New “Seventh Element” of Compliance: Screening and Evaluating Employee Suitability!

The recently issued Resource Guide for Measuring Compliance Program Effectiveness, reconfigures the traditional formulation of the “Seven Elements of an Effective Compliance Program by making the “Screening and Evaluation of Employees, Physicians, Vendors and other Agents” an element unto itself – or the new “Seventh Element of Compliance!” The Resource Guide, a product of roundtable discussions […] more>>

Excluded Dentist Pays Record $1.1 Million and Agrees to 50 Year Exclusion

Exclusion Violation by Dentist "Sends a Strong Warning" February 1, 2017 By Paul Weidenfeld The Office of the Inspector General's (OIG) announced last week that it had reached a settlement in excess of a million dollars with an excluded dentist for violations of the provisions of the regulations denying participation in federal health care programs […] more>>

OIG Issues Final Rule Expanding Exclusion Authority

By Paul Weidenfeld January 23, 2017 On January 12, 2017, the Office of Inspector General published a final rule finalizing revisions to its exclusion authorities. The final rule makes changes to key definitions that could have a significant impact on providers by broadening the scope of their exclusion screening obligation and enhancing exclusion enforcement by […] more>>

DOJ Announces $4.7B in FCA Recoveries: What Does It Mean?

DOJ Announces $4.7 billion in False Claims Act Recoveries By Paul Weidenfeld December 16, 2016 The “Third Best Year” in False Claims Act History? The Department of Justice announced earlier this week that FY 2016 was its third best year in “False Claims Act History” with recoveries of more than $4.7 billion in settlements and judgments. […] more>>

What Medical Practices Need to Know About an OIG Exclusion

By Paul Weidenfeld [1] The Office of Inspector General (OIG) has steadily increased its enforcement of OIG Exclusion violations since the issuance of its Special Advisory stressing the effect of an OIG Exclusion in May, 2013. Among other things, they have created a special unit to focus specifically on  Civil Money Penalties (CMPs) (its favored enforcement tool), supported numerous prosecutions […] more>>

DOJ Doubles Down on False Claims Act Penalties!

  By Robert W. Liles.  August 3, 2016.  The False Claims Act is the primary civil enforcement tool utilized by the federal government in its fight against fraud generally, and, in particular, Medicare and Medicaid Fraud.[1]  Already an extraordinarily useful statute forgovernment prosecutors both in termsof ease of use and in terms of the penalties and damages that may […] more>>

Medicare Exclusion Checks Will be Audited by OIG

By Paul Weidenfeld In October of 2015, the Department of Health and Human Services, Office of Inspector General (HHS/OIG) issued its “Work Plan: Fiscal Year 2016.” The purpose of the Work Plan is to summarize new and ongoing OIG reviews with respect to HHS-programs and operations. Notably, both Medicare Exclusion and Medicaid Exclusion issues will be covered […] more>>

How Compliance Hotlines Can Save Money!

Compliance Hotlines Can Save Money! By Paul Weidenfeld, March 4, 2016.  An essential element of all compliance plans is developing and promoting “effective lines of communications.” In support of that element, Health and Human Services Office of Inspector General (HHS/OIG) has been urging providers to adopt anonymous hotlines since 1998. CMS, on the other hand, […] more>>

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