Tag: fraud and abuse

Can Overpayments Create Criminal Liability?

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We hear a lot about potential liability under the False Claims Act (FCA) for the failure to repay overpayments within 60 days of discovery. Focus on the 60-day rule has taken focus away from the potential for criminal charges for retaining known overpayments.  Section 1128B(a)(3) of the Social S...

New 2016 Work Plan Indicates Area of Compliance Focus

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OIG 2016 Work Plan Highlights Areas of Fraud and Abuse Concern Each year the Office of Inspector General puts out a work plan that indicates the priorities that it will look up at during the upcoming year. The OIG is an organization that was created to protect the integrity of the HHS program ope...

Bad Anesthesia Billing Advice Can Lead To False Claims

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Beware Of Bogus Anesthesia Billing Advice I wanted to alert anesthesia groups to what I consider to be some very bad advice that is being provided by some billing consultants.  If taken, the advice could put your group in the midst of a lawsuit with a third-party payor or even a claim of insura...

60 Day Repayment Rule and False Claims Act

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The 60-Day Repayment Rule and False Claims Act Providers Get Another Push Into Proactive Compliance The Patient and Program Protection Act (“PPACA”) added a number of additional tools to the government’s fraud fighting arsenal.  One of those tools is found in PPACA Section 6402 and require...