In-Depth Articles

How Compliance Hotlines Can Save You 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 compliance hotlines since 1998. CMS, on the other hand, actually requires that Fee-For-Service… more>>

Southern District of New York Provides Clarity on “Identifying” Overpayments

In early August of 2015, the Southern District of New York (SDNY) provided insight as to when the 60-day clock for returning an overpayment begins to run under the Patient Protection and Affordable Care Act of 2010 (ACA). This decision is particularly relevant to screening for exclusions because the government has started to penalize providers who… more>>

Medicare and Medicaid Exclusion Screening Compliance: A Challenging Problem with a Surprisingly Simple Solution©

Since August 2014, the Office of Inspector General (OIG) has collected roughly $3.75 Million in Civil Money Penalties (CMPs) in cases involving the employment of persons that have been “excluded” from Medicare. This amount exceeds the total CMPs assessed by OIG on this issue in all of 2013. This continues an established trend. The number of exclusion… more>>

OIG’s Updated Special Advisory Bulletin on the Effect of Exclusions

The Office of the Inspector General (OIG) Broadly Interprets Exclusion Regulations OIG's Demonstrated Interest in Exclusion Screening and Forewarning of Increased Enforcement Efforts By Paul Weidenfeld The OIG's Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs[1] explains the types of conduct that could violate the payment prohibition, which regards items or services provided… more>>

HCFAC Report 2014: After Consecutive Record Years, Recoveries and Prosecutions Dip, but Exclusions Continue to Increase

The Health Care Fraud and Abuse Control Program1 (“HCFAC”) prepares detailed yearly reports which are sometimes viewed to be a barometer of fraud and abuse enforcement efforts. Valid conclusions can’t be drawn based on small samples or on numbers alone. However, side by side comparisons of data or even over a short period of time may be suggestive… more>>

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