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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 Exclusion List, Industry News, OIG, Medicaid, Medicare, Fraud and Abuse, Penalties and Fines

Healthcare Fraud: From CEO to CE NO

Posted by Michael Rosen, ESQ on Tue, Oct 11, 2016

Former Chief Executive of South Carolina Hospital Pays $1 Million and Agrees to OIG Exclusion to Settle Claims Related to Illegal Payments to Referring Physicians

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OIG Exclusion List, Industry News, OIG, CMS, Medicaid, Medicare, Fraud and Abuse, Penalties and Fines

Delays in Reporting OIG Exclusions: Florida can't Blame the Hurricane

Posted by Michael Rosen, ESQ on Thu, Jun 16, 2016

The OIG reviewed the performance of the Florida state Medicaid Fraud Control Unit  ("Unit") (2015 Onsite Review) and released its findings in June 2016. The OIG found that the Unit did not report all convictions and adverse actions to the Federal government as required by Performance Standard 8(f) within required timeframes.

Performance Standard 8(f) states that a Unit should transmit to the federal OIG "reports of all convictions for the purpose of exclusion from Federal health care programs, within 30 days of sentencing."  The Unit reported their staff erred in failing to follow guidelines and to report convictions and adverse actions within the required time frames.  

Further, the OIG found that of the 193 convictions obtained by the Unit half did not report within required time frame (30 days of sentencing) and 10 did report prior to the onsite review.  

Of the convictions they did report:

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OIG Exclusion List, Industry News, Healthcare Compliance, OIG, Medicaid, Medicare, Fraud and Abuse, Penalties and Fines

48-year OIG exclusion deemed fair for $200 million in fraud

Posted by Michael Rosen, ESQ on Tue, May 10, 2016

Forty-eight years is practically half a century. It is also the amount of time an excluded physician received and was upheld by the Administrative Law Judge (ALJ) in  a recent appeal in Louisiana. This case tested the tenets of the exclusion authority and factors that can be taken into account when issuing an exclusion term.  

In Zahid Imran, M.D. v. OIG (2016 BL 111001, HHS Departmental Appeals Bd., Appellate Div., Dec. No. 2680, 3/11/16), the board sustained the exclusion of a physician from all federal healthcare programs for 48 years due to the physician's conviction for felony healthcare fraud and the existence of several aggravating factors. Zahid Imran, a physician formerly licensed in Louisiana, pled guilty to one felony count of Medicare fraud based on a six-year long scheme in which he and others admitted patients who either didn't qualify for partial hospitalization or for whom partial hospitalization wasn't medically necessary. As part of the plea agreement, Imran stipulated the calculated loss to Medicare was between $50 million and $200 million. 

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Industry News, Healthcare Compliance, OIG, CMS, Medicaid, Medicare, Fraud and Abuse

The Bundled Payment Initiative and the Healthcare Compliance Industry

Posted by Joey Convertino on Tue, May 03, 2016

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Industry News, Healthcare Compliance, OIG

HHS Inspector General Updates OIG Compliance Guidance on Exclusions

Posted by Michael Rosen, ESQ on Tue, Apr 19, 2016

NOTICE April 18, 2016: Updated OIG exclusion authority 

Inspector General Daniel Levinson presented at the Health Care Compliance Association's Institute conference in Las Vegas about an update on the OIG's compliance guidance and its authority to exclude individuals and/or entities from federally funded healthcare programs.

The OIG introduces a new compliance risk spectrum which will be taken into consideration at the time of exclusion. 

"The OIG will weigh various factors described below in its determination of where a person falls on the compliance risk spectrum. At the Highest Risk end of the spectrum, OIG will pursue exclusion. At the Lower Risk end of the spectrum (cooperative and good faith self-disclosures), OIG will provide an exclusion release without integrity obligations." (pg. 3)

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