Introduction The 2021 Top Management and Performance Challenges Facing HHS is an annual publication of the Department of Health and Human Services (DHHS) Office of Inspector General (OIG). The OIG has identified six t...
The Continuing Rise in Drug Compounding Fraud

When most people think about pharmaceutical fraud, they may envision pharmacy staff shorting a prescription to pocket a few pills and then overcharging the patient, or taking pharmacy inventory to sell on a shady interne...
Employers – Dig Deeper! The Role of Abuse Registries in Employee Screening

There are specific screening requirements for health care employers who receive federal funds as participants in federally-funded health care programs, but screening against abuse registries is an often-overlooked resour...
Exclusions Due to Overpayments – Cautionary Tales

While it seems unlikely that an organization’s mail management can result in exclusion from a federally funded program, many errors seem to be causing major headaches for well-intentioned, high- performing organization...
Vendor Management is a Risky Business

Screening employees and potential hires against federal and state exclusion lists can be relatively straightforward if an organization’s HR department maintains current employee data and utilizes the services offered b...
The Long Reach of the COVID-19 Workplace Safety Protocols

On September 9, 2021, President Biden issued Executive Order 14042 (“Order”) which mandated that federal contractors provide adequate COVID-19 safeguards to their workers performing on or in connection with a federal...
Fraud on the Move – Medical Transportation

Medical transportation companies have been on federal and state regulatory radar for decades, for program integrity concerns such as fraudulent billing practices and patient safety concerns. Currently there are 812 names...
Note to Florida Scammers: Exclusion Status Matters to Prosecutors

In April of 2021, defendants Stephanie Fleming and Helen Storey were convicted of multiple counts of health care fraud in federal district court in Florida. The defendants were found guilty of conspiracy to commit health...
OFAC AND ITS IMPACT ON THE TALIBAN

With recent events in Afghanistan, the role of the Treasury Department’s Office of Foreign Assets Control (OFAC) in controlling the release of funds held in US financial institutions by foreign countries or terrorist o...