In November, the Office of Inspector General (OIG) issued its fiscal year 2016 Work Plan giving the industry insight as to the new and ongoing priorities of the OIG. The Work Plan summarizes the prior year’s results, which reflect the OIG’s progression toward an increasing focus on civil actions between […]
Health Law Alert
TCPA Compliance – What’s That?
When is the last time your organization reviewed its Telephone Communications Protection Act (TCPA) compliance policy? With recent clarifications to the TCPA made by the Federal Communications Commission (FCC), now may be the time to pull your TCPA policy off the shelf and give it a once-over. In July 2015, […]
Legislative Update: One-Year Extension of CAH Outpatient Supervision Moratorium
On December 18, 2015, the President signed into law Public Law No. 114-112 which provides a one-year extension, through 2015, of the enforcement moratorium on supervision requirements for outpatient therapeutic procedures at critical access hospitals (CAHs) and small rural hospitals. As a result, the Centers for Medicare and Medicaid Services […]
“Swapping” Arrangements—Now a Sword That Cuts Both Ways
On November 30, 2015, the OIG posted an announcement of a settlement agreement with a skilled nursing facility company, Regent Management Services, L.P. The settlement amounted to approximately $3.199 million in order to resolve allegations that Regent received kickbacks from various ambulance companies in exchange for referrals of Medicare and […]
OIG Study Suggests Increased HIPAA Enforcement
In September 2015, the U.S. Department of Health & Human Services Office of Inspector General (“OIG”) issued two studies concerning the Office for Civil Rights’ (“OCR’s”) oversight of compliance with the HIPAA rules. The first study recommends that OCR strengthen its oversight compliance with the HIPAA Privacy Standards. The second […]

