The following is the Med Law Blog’s Top 10 List for Areas of Interest in the OIG 2010 Work Plan for physicians and providers, which will draw particular scrutiny next year:
1. Medicare Incentive Payment for E-Prescribing
2. Practice Expense Components of Diagnostic Imaging
3. Outpatient Physical Therapy Services by Independent Therapists
4. Place of…
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The Office of Inspector General of the Department of Health and Human Services has just released a report examining problems with incident to billing by physicians, and seeking restrictions on the use of that billing arrangement. The report, titled "Prevalence and Qualifications of Non-Physicians Who Performed Medicare Physician Services" was posed by the OIG on…
On July 29, 2009, the Federal Trade Commission announced that it will again delay enforcement of the Red Flag Rules, this time until November 1, 2009. The Red Flag Rules apply to health care providers who allow patients to pay for health care services, for example through co-payments and deductibles, in installments. For further details…
On August 1, 2009, health care providers will be subject to enforcement of the "Red Flag Rules" issued by the Federal Trade Commission under the Fair and Accurate Credit Transactions Act. The Red Flag Rules apply to health care providers who allow patients to pay for health care services, for example through co-payments and deductibles…
President Obama signed the Fraud Enforcement and Recovery Act of 2009 on May 28, 2009, which is the effective date of the Act.
I am attaching a compared version identifying all the changes, but I would like to direct your attention to what I believe is the most significant change impacting typical healthcare providers.
Retentions …
This new law fixes problems in the False Claims Act, extends whistleblower protections to those who work for contractors and provides new
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In a press release dated April 30, 2009, the FTC indicated that it will delay enforcement of the Red Flag Rules from the original compliance date of May 1, 2009 until August 1, 2009. The FTC indicated that it will soon release a template to assist certain low risk entities in complying with the Rules. As additional…
On May 1, 2009, health care providers will be subject to the "Red Flag Rules" issued by the Federal Trade Commission under the Fair and Accurate Credit Transactions Act. The Red Flag Rules apply to health care providers who allow patients to pay for health care services, for example through co-payments and deductibles, in installments.
On March 24, 2009, the OIG issued an open letter (pdf) to healthcare providers restricting the application of the OIG Self-Disclosure Protocol (SDP).
The open letter states clearly that OIG is "narrowing the SDP’s scope regarding the physician’s self-referral law." This action has two components.
First, the OIG will accept providers into the SDP only when…
