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Only two days after releasing its latest fraud alert, a deputy director from HHS’s Office of Inspector General announced that the OIG will be hiring additional attorneys to look into taking more administrative actions against physicians in their individual capacity. This announcement emphasizes that the OIG means serious business – not only is the OIG shifting its focus to the physicians themselves, but it is hiring a team of attorneys as further enforcement. In…
Board members for organizations of all sizes need to be familiar with the OIG’s recent publication of Practical Guidance for Health Care Governing Boards on Compliance Oversight. This informative guide is intended to assist the Board member of any health care organization fulfil compliance obligations with the myriad of health care laws and regulations.  Although acknowledging that there is no “one size fits all” approach to compliance, the guidance emphasizes the importance of compliance…
Just before the ball dropped to start the new year, the Centers for Medicare & Medicaid Services approved the Recovery Audit Contractor (RAC) to identify and recoup improper payments for durable medical equipment, home health and hospice care on a national basis (known as region 5). The contract, dated December 30, 2014, is the first one issued since Recovery Audit contracts were halted last summer. Providers must be vigilant when responding to an audit both…
Squire Patton Boggs attorneys recently published an article that discussed three anti-fraud elements of the Affordable Care Act (ACA) regarding maintaining financial integrity of the health insurance exchanges. Looking at those provisions, some may erroneously conclude that the ACA dramatically increased the damages that may be imposed for false claims made in connection with the exchanges. The article analyzes the three anti-fraud elements and concludes that only two made it into law: (1) the FCA…
It’s another record haul for the United States Department of Justice! In FY 2014, the DOJ ensured the collection of more than $ 24 billion from civil and criminal actions. The False Claims Act yielded a substantial portion of that total by having its own record setting recovery of $ 5.69 billion. Healthcare fraud recoveries under the False Claims Act amounted to $ 2.3 billion, which makes this the fifth consecutive year in which such…