CMS published the 2015 Open Payment Data on June 30, 2015. This is the link to the notice and the CMS site: https://openpaymentsdata.cms.gov/
CMS has presented tables in its press release showing the highest paid specialties and highest paying companies. Over the last two years, Novartis has paid approximately $842 million to 344,000 recipients, which…
On October 21, 2015 the Department of Health and Human Services Office of Inspector General posted Advisory Opinion No. 15-13. This Opinion relates to a request for Advisory Opinion about a plan to offer free van shuttle services to certain medical facilities in an integrated health system. The Office of Inspector General (the “OIG”) …
In July 2015, CMS released proposals to provide several new Stark Law exceptions and to clarify issues regarding existing exceptions. Over the next few days, I will post comment on what I consider the most significant new exceptions and clarifications. The full text of these proposal and CMS comments and explanations is available at:
Microsoft recently announced that, after April 8, 2014, it will not longer provide security updates or technical support for Windows XP. Microsoft’s statement that “businesses that are governed by regulatory obligations such as HIPAA may find that they are no longer able to satisfy compliance requirements” has spurred a certain level of panic among health…
The Department of Health and Human Services (HHS) has released a proposed rule that would modify the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule by allowing health care providers to make certain disclosures to the National Instant Criminal Background Check System (NICS). The NICS aims to keep guns from being sold to those…
In OIG Advisory Opinion No. 13-03, the Office of Inspector General had the opportunity to deal with two issues which have always raised concerns in the past, i.e. pod labs and swapping. It is no surprise that OIG refused to issue a favorable advisory opinion regarding these issues, and one suspects the request was submitted…
The OIG has issued a Special Fraud Alert, dated March 26, 2013, describing specific attributes and practices of Physician Owned Distributorships (PODs) believed to produce substantial fraud and abuse risk and pose dangers to patient safety.
PODs are physician owned entities that derive revenue from selling or arranging for the sale of implantable medical…
OIG Advisory Opinion No. 12-15 has approved an existing arrangement under which a hospital pays physicians a per diem fee for providing on call ER coverage.
Under the arrangement, the hospital pays per diem fees to 130 specialty physicians on staff who provide on-call services, including:
· telephone consultations;
· in-person consultations, as…
EXECUTIVE SUMMARY: QUESTIONABLE BILLING FOR MEDICARE INDEPENDENT DIAGNOSTIC TESTING FACILITY SERVICES
OEI-09-09-00380
WHY WE DID THIS STUDY
Independent Diagnostic Testing Facilities (IDTF), a type of Medicare provider, offer diagnostic services and are independent of physicians’ offices or hospitals. IDTF services have historically been vulnerable to abuse. In 1997, the Office of Inspector General found that…
The Healthcare Fraud Prevention and Enforcement Action Team (HEAT) and the Office of Inspector General have posted a Toolkit consisting of a series of podcast training videos on the following subjects:
· How to Use the Exclusions Database
· How to Report Fraud to the OIG
· OIG’s Self-Disclosure Protocol
· …
