It’s not uncommon for labs to place a phlebotomist in a physician’s office to collect and process samples for testing. While not strictly illegal, this practice raises bright red flags under kickback … [Read more...]
ANTI-KICKBACK
Compliance Perspectives: 5 Ways to Avoid Kickback Risks When Placing Phlebotomists in Ordering Physician’s Offices
December 12, 2019
Anti-Kickback
Special Report: Long Awaited Kickback Relief Rules Keep Labs in the Cold
October 22, 2019
They’re finally here! After years of talking about adapting the decades-old kickback laws to modern medical market conditions, CMS and OIG proposed new rules (the Proposal) on Oct. 9, 2019. Whether it … [Read more...]
COMPLIANCE GUIDANCE
Stark Law: CMS Plan Would Make It Easier for Labs to Get Advisory Opinions
September 9, 2019
In late July, CMS proposed to update the advisory opinion process that labs and other providers use to get a determination about whether a proposed business arrangement would violate the Stark Law. … [Read more...]
COMPLIANCE GUIDANCE
HIPAA: New HIPAA Penalties System Rewards Labs that Try to Comply
August 12, 2019
New HHS rules significantly increase the amount of money your lab can save by making diligent and demonstrable efforts to prevent HIPAA violations even when those efforts don't succeed. We're … [Read more...]
COMPLIANCE GUIDANCE
Enforcement Trends: DOJ Changes to Yates Memo Make It Easier for Labs to Get Credit for Cooperating with Investigators
July 1, 2019
For the past five years, the DOJ has followed an enforcement policy designed to hold directors, officers and other top corporate officials responsible for the wrongdoing their companies commit. Last … [Read more...]
DOJ
Compliance Perspectives: Use New DOJ Criteria to Vet the Effectiveness of Your Lab Compliance Program
June 28, 2019
One of the primary responsibilities of a lab manager is to ensure that the lab's compliance program is effective. There's a lot on the line. Having an effective compliance program can help prevent … [Read more...]
COMPLIANCE
DOJ Explains What It Wants from a Compliance Program
June 17, 2019
While it may not prevent all violations, the right compliance program can help your lab get lighter penalties if things go wrong. But what exactly is "the right compliance program." On April 30, the … [Read more...]
COMPLIANCE GUIDANCE
Brief Your CEO: Explain How New DOJ Guidance Can Get Your Lab Out of FCA Hot Water
June 10, 2019
New guidance from the DOJ lays out sheds light on a crucial matter that many high-ranking lab executives are forced to confront: whether to "play ball" with the federal government when internal … [Read more...]
COMPLIANCE CORNER
Cybersecurity: The 10 Things HHS Says You Should Be Doing to Stop Phishing, Ransomware and Other Threats
February 18, 2019
HHS published guidance on cybersecurity for healthcare organizations. Even though it's voluntary, the new HHS Guidance is significant to the extent it lays out the agency's expectations of the … [Read more...]
COMPLIANCE GUIDANCE
Compliance Perspectives: Avoid Kickback Liability by Steering Clear of MD Processing Fees
December 10, 2018
Editor's Note: Two months ago, we talked about paying referring physicians a fee for collecting and processing blood, urine, tissue and other specimens. (G2 Compliance Advisor, Oct. 9, 2018, p. 1). … [Read more...]
