On June 9, 2015, the OIG issued a Fraud Alert entitled “Fraud Alert: Physician Compensation Arrangements May Result in Significant Liability”. This is just a one page letter warning hospitals and physicians by stating the OIG recently reached settlements with 12 individual physicians who entered into questionable medical directorship and office staff arrangements;
Office of Inspector General
OIG Rejects Specialty Pharmacy Request to Pay “Per-Fill” Payents to Retail Pharmacies
By Michael Cassidy on
Posted in Compliance
In OIG Advisory Opinion 14-06, the Office of Inspector General (OIG) concluded that payment by a specialty pharmacy to a retail pharmacy on a “per-fill” basis for services provided by the retail pharmacy could violate the Anti Kickback Statute and Civil Money Penalty provisions.
The specialty pharmacy, as the requestor, proposed to pay retail…
OIG Finds Privacy and Security Risks with ONC EHR Certification Process
By Michael Cassidy on
Posted in Compliance
It is ironic to learn the Office of Inspector General (OIG) believes the Office of the National Coordinator for Health Information Technology (ONC) essentially has an insufficient compliance program to maintain the privacy and security of the protected health information (PHI) hosted by electronic health records (EHR).
In an August 2014 report (A-06-11-00063), OIG concluded…
OIG Report: Questionable Billing for Medicare Part B Clinical Laboratory Services
By Michael Cassidy on
Posted in Compliance
Perhaps not coincidentally, immediately following the release of the Questionable Laboratory Payments Special Fraud Alert by the OIG, posted yesterday on the Med Law Blog, the OIG has followed up with Audit Report OIG – 03-11-00730: Questionable Billing for Medicare Part B Clinical Laboratory Services. Below are two quoted paragraphs from the executive…
Anti-Kickback Laboratory Enforcement Actions – Special Fraud Alert
By Michael Cassidy on
Posted in Compliance
There has been significantly enhanced scrutiny of financial relationships between referring physicians by both the Office of Inspector General (OIG) and Pennsylvania authorities.
Pennsylvania
Pennsylvania enacted amendments to the Pennsylvania Clinical Laboratory Act on December 18, 2013 (the amendments are referred to as Act 122) and the Department of Health and Bureau of Laboratories just…