The Office of Inspector General (OIG) is not the only source for exclusions. Did you know that the state Medicaid agency and/or State Attorney General, if applicable, in each state must report its actions to the Federal OIG promptly after the agency takes a final action? (Social Security Act 1902(a)(41) and 42 CFR 1002.3(b)(3). In this article, we'll take a look at how well reporting has taken place given the latest OIG research data, and compare Q1 2017 results from our latest CHIRP report.Read More
Larger healthcare companies typically employ an entire and robust legal department in-house to handle legal work and provide good counsel to management and senior executives. Some of these companies will hire outside counsel to supplement areas of expertise that may be lacking by an internal department. But what happens when that advice or legal counsel is considered to be fraudulent? Who is liable? Who takes the fall and can be subject to the long arm of the law?Read More
Which states have the most exclusions? Glad you asked! First off, did you know that there are 40 states that have a state Medicaid exclusion list in addition to the two federal exclusion datasources (OIG-LEIE and SAM.gov)? Did you also know that a state Attorney General’s Office and/or Medicaid Agency can impose an exclusion on a person or entity in addition to the OIG? In today’s compliance environment, it’s important to have a comprehensive monitoring program that is placing just as much emphasis at the state level to achieve 100% compliance.Read More
You found an excluded employee in your organization, now what? Likely, your first thought is a bit of panic and a lot of questions. How long has this person worked for us? How did we miss this? What position did they hold? Did we receive federal funds for the job this person held? What do I do now? If there is any good news in this scenario, perhaps it is that the Office of Inspector General (OIG) has given providers direction on how to prepare for a self-disclosure to the OIG via the OIG’s Provider Self-Disclosure Protocol (SDP) document.Read More
Have you heard of the OIG’s Work Plan? Effective June 15, The OIG announced that it will update its Work Plan website monthly and provide more timely information. Usually, compliance professionals have been accustomed to receiving annual OIG Work Plans between August and October, and possibly an update once a year on the progress. Let’s take a look at some of the new features and content.Read More
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