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 ...

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...

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...

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...

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...

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...

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...

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...