With the New Year Comes the Time for a New Compliance Annual Work Plan: Suggested Tips in Meeting the Challenge
The beginning of a new year brings with it a challenge for compliance officers. Now is the time that compliance…
When Moving to a Corporate Integrity Agreement, Think Ahead to Avoid Problems Later
Recent high-profile cases involving Corporate Integrity Agreements (CIAs) such as Tuomey Healthcare System and Millennium Health (formerly Millennium Labs) remind…
Board Level Mandates in Corporate Integrity Agreements
Over the years, the OIG has used Corporate Integrity Agreements (CIAs) to advance policies requiring organizations to maintain compliance with…
OIG to Audit the Office of Civil Rights Oversight of HIPAA Security
The HHS OIG recently released its annual Work Plan for Fiscal Year (FY) 2016. The Work Plan outlines planned audits…
CMS Penalizes More Than 700 Hospitals for High Rates of Hospital-Acquired Conditions
In FY 2015, CMS began reducing Medicare payments for hospitals that rank in the worst-performing quartile for hospital-acquired conditions (HACs).…
OCR Enters into a $750,000 HIPAA Settlement for Organization’s Failure to Implement Effective Policies and Procedures
The HHS Office for Civil Rights (OCR) has entered into a settlement agreement with the University of Washington Medicine (UWM)…
Yates Memorandum: What Steps Compliance Officers Should Take
This is the second blog in a series regarding the Deputy Attorney General Sally Yates’ memorandum (“Yates Memo”), which emphasizes…
False Claims Act Whistleblowers Lead to $2.8 Billion in Recoveries
The DOJ reported that the Civil Division recovered $2.8 billion in fiscal year (FY) 2015 as a result of 638…
Sanction Screening Tips for Compliance Officers: HHS OIG Reports Taking Over 4,200 Administrative Sanctions in 2015
Various Federal laws provide the authority to impose administrative sanctions for fraud and abuse, as well as for other activities…
Independent Auditor (IA) Validation Process for Medicare Part C and D Program Audits
CMS has issued an updated memorandum mandating an Independent Auditor (IA) Validation Process for Medicare Advantage and Prescription Drug Plan…
OIG Advisory Opinion No. 15-14
The OIG issued an advisory opinion regarding a non-profit, tax-exempt, charitable organization’s (“Requestor’s”) program (the “Arrangement”) to help financially needy…
Reflections on the “Yates Memo” and New DOJ Guidelines
This blog release is a part of a series of articles relating to the memorandum by Deputy Attorney General Sally…