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The Federal Government Really Wants You to Take Self Disclose

Posted on May 28, 2019 by admin
The Department of Justice (DOJ) along with other health care fraud enforcement agencies, continue to send strong signals that they want businesses to police themselves for potential compliance issues and self-disclose where infractions are found.  The fact of the matter is the government simply ...
Posted in UncategorizedTagged 2016 Work Plan

The Essence of Compliance – Compliance Officer Authority and Resource Allocation

Posted on May 24, 2019 by admin
How Are Compliance Budgeting and Compliance Officer Autonomy Tied Together When Assessing Compliance Effectiveness? The Department of Justice (“DOJ”)’s compliance program evaluation identifies the need to allocate sufficient revenues to the compliance program as one of the key issues that i...
Posted in UncategorizedTagged 2016 Work Plan

HIPAA This, HIPAA That. Everything is a HIPAA Issue. Deconstructing the "HIPAA Bias."

Posted on May 22, 2019 by admin
HIPAA, as a body of regulations protecting the confidentiality of patient health care information, has been branded very effectively.  Most staff at your average health care facility know about HIPAA and that it protects the confidentiality of a patient’s health care information.  They unders...
Posted in UncategorizedTagged 2016 Work Plan

DOJs New Evaluation of Corporate Compliance Programs – A Good Time to Focus on the Essence of Compliance

Posted on May 20, 2019 by admin
The Criminal Division of the United States Department of Justice (DOJ) recently released an update (April, 2019) to its Evaluation of Corporate Compliance Programs (Evaluation).  The Evaluation was first introduced in 2017 to provide guidance for prosecutors to consider when conducting investiga...
Posted in UncategorizedTagged 2016 Work Plan

New CMS Rules for Inpatient Rehabilitation

Posted on May 13, 2019 by admin
Well, it’s a start.  New Medicare rules kicked in starting January 1, 2019 that are aimed at focusing less provider time on paperwork and more on patient care in inpatient rehabilitation facilities.  Any change that reduces paperwork in this overregulated area is welcome, but the actual impac...
Posted in UncategorizedTagged 2016 Work Plan

Telemedicine IT Donations and the Anti-kickback Statute – OIG Opinion 18-03

Posted on October 29, 2018 by admin
IT Donation to Facilitate Telemedicine Consultations – Low Risk of Fraud says OIG The Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 18-03 in support of an arrangement where a federally qualified health center look-alike (...
Posted in UncategorizedTagged 2016 Work Plan

CMS Proposes Rule to Ease Compliance Requirements

Posted on October 22, 2018 by admin
Last month, the Centers for Medicare and Medicaid Services (CMS) announced a proposed rule designed to, in CMS’s words, “relieve burden on healthcare providers by removing unnecessary, obsolete or excessively burdensome Medicare compliance requirements for healthcare facilities”.  CMS esti...
Posted in UncategorizedTagged 2016 Work Plan

OIG Opinion on Donation of Telehealth Equipment

Posted on September 5, 2018 by admin
A recent Advisory Opinion (Advisory Opinion 18-03) from the Office of Inspector General (OIG) of the Department of Health and Human Services addresses potential kickback issues involved in the donation of telehealth equipment.  The OIG has issued opinions addressing technology donation in the pa...
Posted in UncategorizedTagged 2016 Work Plan

Hospital Program for Free Support Services for Caregivers – Approved by OIG

Posted on August 30, 2018 by admin
A recent Office of Inspector General (OIG) advisory opinion approved a proposal under which a hospital has established a caregiver center that provides or arranges for free or reduced-cost support services to caregivers in the local community (Arrangement).  The OIG, basing its opinion on the fa...
Posted in UncategorizedTagged 2016 Work Plan

Ruder Ware Health Care and Compliance Attorney Receives Top Award

Posted on August 28, 2018April 29, 2020 by admin
Ruder Ware health care and compliance attorney John Fisher has received top recognition from JDSupra, a leading national legal blogging platform and resource site.  Mr. Fisher received the 2018 Reader’s Choice Award from JDSupra in two separate categories, Health Care and Compliance.  Mr. Fis...
Posted in UncategorizedTagged 2016 Work Plan

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