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The ProviderTrust Blog

Your source for healthcare compliance news, advice from industry experts, and all things related to OIG exclusions.

OIG, compliance, corporate integrity agreements

Corporate Integrity Agreements: A Brief History

Posted by Michael Rosen, ESQ on Tue, Apr 18, 2017

A CIA is a serious weapon available to the OIG to resolve allegations of fraud and abuse. Let's take a look back at some of the history of Corporate Integrity Agreements and how they are used.

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OIG, compliance, corporate integrity agreements, compliance officer

What’s New in Corporate Integrity Agreements from the OIG?

Posted by Donna Thiel on Thu, Apr 13, 2017

As we all know, Corporate Integrity Agreements (CIA’s) are an excellent resource to a compliance officer when trying to stay ahead of the ever-changing compliance landscape. CIA’s provide a wealth of information as to what the Office of Inspector General (OIG) believes should be elements of an effective compliance program. They can also help clarify roles and responsibilities of the board or senior leadership in a healthcare organization. It is highly recommended that you monitor CIAs posted on the OIG site on a periodic basis to see if the model CIA has been updated or changed.

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ProviderTrust News, compliance, HCCA, HCCAci

Everything You Need to Know for HCCA CI 2017

Posted by Michael Rosen, ESQ on Thu, Mar 23, 2017

HCCA Compliance Institute begins this weekend, and year after year, it never disappoints! At ProviderTrust,
meeting new faces and reuniting with friends has always been our favorite part of this enjoyable event.

As we prep for our journey to the National Harbor in Maryland, we made it a priority to put together some resources for you - in the event you get to go - so that you get the most out of your HCCA CI 2017 experience!

Take a look below to start planning, and be sure to say hello if you see us.

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Fraud and Abuse, Penalties and Fines, compliance, false claims act

Three Times is Not a Charm: Court Triples Whistleblower Damages

Posted by Michael Rosen, ESQ on Tue, Mar 21, 2017

Here is a fast moving case to watch and one that has a not so happy outcome. On March 1, 2017, a Florida federal judge awarded the U.S. and Florida governments more than $347M in trebled (three times) damages following a jury trial in a False Claims Act case. This case has many aspects that make it unique and costly, but one interesting fact is that it was a rare case in which the case went to trial and received a jury verdict of $115M in a False Claims Act case. 

The case highlights a major concern for the OIG, as outlined in the 2017 OIG Work Plan. The OIG Work Plan specifically addresses nursing home/facility fraud concerns, stating that, "Previous OIG work found that (skilled nursing facilities) are billing for higher levels of therapy that were provided or were reasonable or necessary." So the OIG proposed to and, in this case, reviewed documentation at selected skilled nursing facilities to determine it met the requirements for each particular resource utilization group. The involved sophisticated data mining and analytics, now deployed at the OIG.
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Fraud and Abuse, compliance, Compliance Audit

We Told You It was Going to Get Personal

Posted by Michael Rosen, ESQ on Thu, Mar 16, 2017

Healthcare liability is getting personal. Following the Sally Yates Memo, the DOJ has set certain guidelines and let it be known that they will pursue the individuals personally for their role in committing fraud.

In this blog we discuss a few cases that show that although Sally Yates may not personally be there to lead the charge, but the bull is definitely out of the cage. 

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