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Posts tagged "OIG"

OIG Issues Resource Guide For Measuring Effectiveness of Corporate Compliance Programs

On March 27, 2017, the Office of the Inspector General ("OIG") posted a Resource Guide for Measuring Compliance Program Effectiveness. You can access the OIG's Guide here. The Guide is organized under the following "elements" that should be addressed under an organization's Compliance Program:

Government Continues To Focus On Therapy Issues In Nursing Homes

The provision of therapy services continues to be a focal point of government regulators. In its 2016 Work Plan, the OIG states that it will continue to review the provision of therapy in nursing homes, citing past findings of overutilization and fraudulent billing of such services. The OIG, in conjunction with the U.S. Department of Justice, has been active in prosecuting alleged therapy billing compliance issues, resulting in multi-million dollar settlements with nursing home providers, with several high-profile investigations still pending. RAC and ZPIC audits focusing on therapy services continue throughout the country. In September 2015, the OIG issued a report entitled "The Medicare Payment System For Skilled Nursing Facilities Needs To Be Reevaluated" which concluded that Medicare payments for therapy services greatly exceeded nursing facility costs, and that the current system encourages nursing homes to bill therapy services at the highest levels possible, in order to maximize reimbursement, without a corresponding demonstration of beneficiary need.

OIG Issues New Compliance Guidance for Health Care Boards

On April 20, 2015, the OIG released a document entitled "Practical Guidance for Health Care Governing Boards on Compliance Oversight." http://oig.hhs.gov/newsroom/news-releases/2015/guidance-release2015.asp

OIG Releases 2015 Work Plan

The OIG's 2015 Work Plan has been posted to its website and is available for review by providers. The Work Plan describes the activities and investigations planned by the OIG for 2015 and breaks down those plans by provider type. For long-term and post-acute providers, pertinent highlights include:

OIG Clarification on Medicare Exclusion Process

On May 8, 2013, the Office of Inspector General ("OIG") issued an Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs. Previously, the only official guidance from OIG on the scope and effect of its exclusion from participation was published in its 1999 Special Advisory Bulletin, which the Updated Bulletin replaces and supersedes. An OIG exclusion is a legal prohibition on payment by Federal health care programs, such as Medicare and Medicaid, for items or services furnished by (1) an excluded person or (2) at the medical direction or on the prescription of an excluded person. This prohibition extends beyond direct patient care and reaches administrative and management services payable by Federal health care programs.

CMS Issues Clarification on NF Compliance Program Mandate

As we recently reported, Section 6102 of the Affordable Care Act ("ACA") requires all nursing facility providers to have a Corporate Compliance Plan in effect by March 23, 2013. While the ACA required the Office of the Inspector General ("OIG") to promulgate regulations to provide guidance to facilities on the content, scope and requirements of this mandate, to date, the OIG has yet to issue any written materials.  Last week, CMS advised that it is likely that such regulations will not be issued until later in 2013.  CMS further stated that it will not enforce the statutory mandate until final regulations are issued. In the interim, providers should continue their existing compliance efforts, consistent with current guidance promulgated by the OIG.

Compliance Plan Mandate - March 23, 2013 Deadline Approaching

The Affordable Care Act ("ACA") requires all nursing facility providers to have a Corporate Compliance Plan in effect by March 23, 2013. While the ACA required the Office of the Inspector General ("OIG") to promulgate regulations to provide guidance to facilities on the content, scope and requirements of this mandate, to date, the OIG has yet to issue any written materials. However, despite this failure to act, the statutory deadline imposed by the ACA remains in effect.

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