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The ProviderTrust Blog

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

Healthcare Compliance, OIG, Fraud and Abuse, Penalties and Fines, Self Disclosure

SEC: No way to legally prevent the Whistle from being blown

Posted by Michael Rosen, ESQ on Thu, Oct 13, 2016

 The Securities and Exchange Commission (SEC) recently fined two public companies for including within severance agreements a provision designed to eliminate a former employee's right to recover whistleblower incentives. (BlueLinx Holdings and Health Net, Inc.)

In what is generally considered a standard provision, the companies' agreements allowed for the former employee's participation in any government investigation but required a waiver of the right to recover any incentive payments the law provides for whistleblowing in healthcare.

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OIG Exclusion List, Healthcare Compliance, OIG, CMS, Self Disclosure, Sanction Screening, License Verification

More Scrutiny to Sell Weed in Colorado than to Get a Medical License

Posted by Michael Rosen, ESQ on Tue, Jul 12, 2016

Colarado high takes on a new meaning. When you compare the requirements to become a licensed medical marijuana dealer in Colorado to that of the scrutiny conducted by the Colorado Board of Nursing, you would be surprised which is harder to get. The Colorado Dept. of Revenue, Enforcement Division, will actually conduct a background check on an applicant for medical marijuana dealer, and the Colorado Nursing Board will not.

According to a recent article in the Denver Post, it is one of six states that do not require a background check in order to get a nurse license.  

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OIG Exclusion List, Healthcare Compliance, OIG, OIG Work Plan, Self Disclosure

Avoiding Risks in Your Healthcare Compliance Plan

Posted by Michael Rosen, ESQ on Tue, Jun 14, 2016

Effective compliance planning is demonstrated and driven by outcome.

The most important step in creating an effective compliance plan for your organization is to be proactive in actually implementing its terms. Leaving a compliance plan on a shelf collecting dust, as if an afterthought, sends the wrong message to prosecutors especially if an audit of your organization should find any excluded individuals or entities, or other non compliance.

The first steps towards compliance are having a plan in place. In some respects, that is the easy part. Not only is it required to have a compliance plan in some fields of healthcare, but it is also a building block for an organization’s compliance success.

This just goes to show it's not just words on paper, but it is a document outlining how you will be held responsible for adhering to its terms. Not adhering to its terms can lead to a forced Corporate Integrity Agreement (CIA) with the OIG along with hefty fines.

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OIG Exclusion List, Healthcare Compliance, OIG, Affordable Care Act, Medicaid, Medicare, Fraud and Abuse, Penalties and Fines, Human Resources, Self Disclosure, Sanction Screening, Long Term Care

The Ultimate Guide to OIG Exclusions

Posted by Michael Rosen, ESQ on Tue, Nov 03, 2015

The Ultimate Guide to Exclusions is a one-stop-shop for everything you need to know about OIG exclusions. This all inclusive guide covers the basics of exclusions, the background of the OIG, the fines and penalties surrounding an exclusion and explains the differences between the OIG exclusion databases. It also leaves you, the reader, with healthcare compliance industry best practices and additional resources! 

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OIG Exclusion List, Industry News, OIG, CMS, Fraud and Abuse, Penalties and Fines, Self Disclosure

Forget March Madness: February OIG Fines Frenzy

Posted by Mike Rosen on Thu, Mar 19, 2015

 
February was a cold month for most of the country. Sleet, Snow, Flurries and Fines. Wait- fines?

The Office of Inspector General weathered the storms well by imposing 6 Civil and Monetary Fines (CMP) involving excluded providers from January 30th to February 25th. The fines totaled $965,663.99. An astonishing tally for 7 people.  The company's settled with the OIG after self-disclosing, in all but one case. 

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