OIG’s Updated Provider Self-Disclosure Protocol: Sampling and Overpayment Extrapolation
On April 17, 2013, the US Department of Health and Human Services (HHS) Office of the Inspector General (OIG) released an Updated OIG’s…
Meeting the Challenge of Adequately Addressing Numerous Compliance Risks
Health care organizations are confronted by a vast array of complicated compliance risks. Although risk issues and areas are often defined by…
The OIG on Screening Against the GSA EPLS
“To obtain/maintain active enrollment status, providers may not employ or contract with individuals/entities excluded from participation in any federal health…
Deficit Reduction Act Mandates Education on Fraud and Whistleblowers
On February 8, 2006, the Deficit Reduction Act of 2005 (DRA) was signed into law. Chapter 3 of Title VI specifically focuses…
Clinical Research and the Sunshine Law: Will the Government Publish Your Name?
Currently, two regulatory events are traveling along side of each other, but not yet intersecting. That will change next year. The two regulations…
What Kind of Compliance Training Program is the Most Effective?
What Kind of Compliance Training Program is the Most Effective? Development and implementation of regular, effective education and training programs…
When and How Should a Hotline Vendor be Re-Evaluated?
Most healthcare organizations have been using the same hotline vendor for many years. Over time, advanced technology and enhanced methodologies…
Biggest Mistakes With Sanction Screening
With the Office of Inspector General (OIG), CMS, and State Medicaid Agencies all calling for increased and more frequent sanction screening,…
Compliance Officer Role Central to an Effective Program
The Department of Health and Human Services Office of Inspector General (OIG) guidance states that the Compliance Officer should serve as…
Tips to Mitigate the GSA Sanction Screening Burden
CMS is the only government agency really pushing screening against the Excluded Parties Lists System (EPLS) (now moved to the System…
Guidelines Followed in Developing and Testing Compliance Surveys
The following guidelines have been followed by the Compliance Resource Center (CRC) for designing and validating their survey tools. Subject…
Conducting an Ethical Climate Assessment Survey for your Organization
The U.S. Sentencing Commission explicitly recognized the significance of “culture” in its 2004 amendments to the Federal Sentencing Guidelines, stating…