Meeting the Privacy Officer Challenge: Outsourcing Might Be the Answer
Imagine discovering an employee’s laptop has been stolen that contained thousands of patient records with protected health information (PHI). Add…
Managed Care Executives at Risk under the OIG Responsible Corporate Officer Doctrine
Managed care organization plan executives are facing increased personal exposure to the OIG’s administrative sanctions under the “Responsible Corporate Officer Doctrine.” In light…
Independent Review Organizations: A Compliance Contract with the HHS Office of Inspector General
On April 12, Thomas Herrmann, a Strategic Management Vice President, held a joint presentation with Felicia Heimer, Senior Counsel, Office…
Taking Control of the CMS Managed Care Audit Process
The creation of the Medicare Parts C & D programs require managed care organizations to develop and implement effective compliance programs. There are…
One Strategy for Rapidly Developing an Effective Compliance Program
For years, there has been a legal and regulatory mandate for managed care organizations (MCOs) to have an effective compliance program — but now the…
Are You Prepared to Pass a CMS Managed Care Audit?
The creation of the Medicare Parts C & D programs carried with it requirements to develop and implement an effective compliance program[1].…
Medicare Part D Compliance: A Day of Reckoning Approaches
The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) [1] established the Medicare Part D outpatient prescription drug benefit, which…
A Glimpse of the Future of Compliance Oversight by CMS: Part D Plans Case Study
Hospitals and other providers should take note of what the Centers for Medicare & Medicaid Services (CMS) is learning from…
Tom Herrmann Discusses the New OIG “Responsible Corporate Officer Doctrine.”
In a recent article published in the Journal of Health Care Compliance, Thomas Herrmann provides his perspective on the new…
The New OIG “Responsible Corporate Officer Doctrine”
The DHHS Office of Inspector General (“OIG”) has raised the stakes for health care executives whose companies become involved in a Federal…
OIG releases 2011 Work Plan with Medicare and Medicaid
OIG releases 2011 Work Plan with Medicare and Medicaid initiatives that will impact hospitals, physicians, Medicare contractors and the Medicare…
Tighter Enrollment Standards for Medical Equipment Suppliers
This article provides details about new regulations impacting medical equipment suppliers and the implications of the tighter enrollment standards. About…