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By Robert Liles (January 5, 2018): Does your health care organization have a compliance hotline / fraud hotline in place? If not, it should implement one as soon as possible. As proof positive that hotlines are effective you only have to check out the most recent hotline activity reported by the Department of Health and […]
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 […]
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 […]
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 […]
On April 18, 2016, the Department of Health and Human Services, Office of Inspector General (HHS-OIG) issued updated criteria for assessing and evaluating the imposition of permissive exclusions under Section 1128(b)(7) of the Social Security Act. The update replaces the 1997 Federal Register notice and demonstrates the OIG’s ongoing interest in the implementation and enforcement […]
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, […]
HHS/OIG Deputy Inspector General Gary Cantrell testified earlier this year that States are failing to report all of the adverse actions taken by their Licensing Boards. He suggested that the “manner and time of the [reported] notices” are unreliable. Cantrell attributed these concerns to the “voluntary” nature of State reporting obligations.[1] I. The Impact on Exclusion […]