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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, Healthcare Compliance, OIG, Medicaid, Medicare, Fraud and Abuse, Penalties and Fines

If there was ever a Case for an OIG Exclusion- this is it.

Posted by Michael Rosen, ESQ on Tue, Mar 01, 2016

An owner of an imaging/diagnostics firm was convicted of fraud, identity theft, false billing and will face life in prison for the deaths of two patients. The CEO and co-owner of a Maryland diagnostics company is facing that sentence after a jury convicted him of two counts of healthcare fraud that resulted in death. The Department of Justice announced last week the results of the court case. 

Results - 

Mr. Rafael Chikvashvili of Baltimore, Maryland was convicted of defrauding Medicare and Medicaid of more than $7.5 million. To make matters worse, “The evidence showed that Rafael Chikvashvili failed to provide medical services to patients who needed them, and billed for services that he did not provide,” said U.S. Attorney Rod J. Rosenstein. “The jury found two patients died because their X-rays were not reviewed by a qualified radiologist. Health care fraud has consequences, in money wasted and lives lost.”

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OIG Exclusion List, Healthcare Compliance, OIG, Medicaid, Medicare, Data Management, ProviderTrust News

CHIRP Q-4: Healthcare Compliance Data Stats are in!

Posted by Michael Rosen, ESQ on Thu, Jan 28, 2016



In 2015, ProviderTrust created CHIRP - the Compliance Healthcare Index Report - to raise awareness of the potential risk to healthcare organizations who do not comply with regulations regarding employment practices. Since then, "CHIRP has been relied upon by many in the healthcare compliance industry as the "go-to" source for all things exclusion data related," says ProviderTrust co-founder Michael Rosen.

And just like a happy bird outside your window on a nice summer evening (we could use that visual after last weeks' EPIC snowstorm), we hope it will awaken you and draw attention to the depths of data available to help your organization stay compliant.

CHIRP identifies where there are gaps in public records that can be misleading or even result in possible exposure to liability. CMS programs (Medicare, Medicaid, TriCare and CHIPS) will not provide reimbursement for facilities that employ any excluded individuals or companies that are found in national and state exclusion databases.

Did you Know?

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OIG, Medicaid, Medicare, Fraud and Abuse

Docs and PODS: Hello Sunshine Act

Posted by Michael Rosen, ESQ on Tue, Dec 29, 2015

We all know what doctors are and that they have to be licensed to practice medicine. But what is a POD and what do they have to do with doctors?

POD —

A POD stands for Physician Owned Distributorship. An example of a POD could be a medical device distributorship of hip replacements, heart pace makers or other devices. The distributorship is owned by a group of physicians and those physicians can order or determine which supplier/device is inserted or purchased for part of the medical treatment provided by the physician. Hence, the need to know if a hospital employed physician is an owner of a POD is critical in order to avoid possible STARK law violations and for transparency, according to the OIG.

According to the OIG, it is not always clear which doctors have ownership interests in both PODS and the hospitals they sell the devices.

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OIG, Medicaid, Medicare, Fraud and Abuse

Medicaid Fraud: Loss of Privileges

Posted by Michael Rosen, ESQ on Tue, Dec 22, 2015

Under 42 C.F.R. § 424.535(a)(12), CMS may revoke the privileges of a supplier if the supplier's Medicaid billing privileges are revoked or terminated by a state Medicaid agency and the supplier has exhausted all applicable appeal rights. 

In a recent case,   Igor Persidsky, M.D./House Calls Medical Corporation v. CMS  (2015 BL 350880, HHS Departmental Appeals Bd., Civil Remedies Div. , Dec. No. CR4309, 10/13/15) the Administrative Law Judge held  that the deactivation of Dr. Persidsky's billing privileges was essentially the same in effect as a termination or revocation of billing privileges because it was an action that prohibited the supplier from billing Medi-Cal. Read More

Healthcare Compliance, OIG, Medicaid, Medicare, Fraud and Abuse, Penalties and Fines

Even the Boss can be Excluded when Healthcare Fraud is Committed

Posted by Michael Rosen, ESQ on Thu, Nov 12, 2015

Culture comes from the top in a healthy compliance oriented health care company. The OIG is serious about enforcing its prohibition of having federal health care dollars flowing to individuals or entities that have committed healthcare fraud and abuse.

How high up the ladder can the OIG go to make their point?  

All the way to the boss.

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