On January 19, 2021, sweeping new regulations related to both the CMS Physician Self-Referral Law (Stark) and OIG’s Anti-Kickback Statute (AKS) went into effect, notwithstanding technical issuance deficiencies.  Related changes to the Civil Monetary Penalty law (CMP) as well as...

The Compliance Institute (CI), a flagship event held by Health Care Compliance Association® (HCCA), has been supporting practitioners with educational and networking opportunities for two and a half decades. This conference offers attendees the latest in real-world compliance issues, emerging...

On December 2, 2021, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) issued its Semiannual Report to Congress for fiscal year 2021 (Report). The Report describes OIG’s work identifying significant risks, problems, abuses,...

Background On December 9, 2021, security researchers discovered a flaw (also referred to as a vulnerability) in the code of a software library used for logging security and performance information. The Apache software library, Log4j, was built on the widely used...

Under federal law, Medicare Advantage plans and Part D plan sponsors may delegate administrative or healthcare service functions to third parties, such as a medical group, pharmacy benefit manager, claims administration organization or hotline vendor. This delegation may cause the...

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 top management challenges that the DHHS currently...

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 internet site.  However, pharmacy-related fraud can...

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 resource for service providers to improve their hiring practices.  While there may...

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 organizations participating in Medicare and Medicaid and programs across the...